Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The HC set aside impugned composite show-cause notices and assessment orders for consolidating multiple tax periods, holding that a single SCN or composite assessment cannot cover more than one tax period (monthly or annual as applicable) and that separate assessments must be framed for each assessment year; divergence in High Courts' precedents noted but statutory interpretation, read with related provisions and the rights to benefits and appeals under the GST framework, requires distinct orders per period. The writ petitions were disposed of, quashing the composite orders and permitting respondents to initiate fresh proceedings confined to each assessment year separately.
The HC set aside impugned composite show-cause notices and assessment orders for consolidating multiple tax periods, holding that a single SCN or composite assessment cannot cover more than one tax period (monthly or annual as applicable) and that separate assessments must be framed for each assessment year; divergence in High Courts' precedents noted but statutory interpretation, read with related provisions and the rights to benefits and appeals under the GST framework, requires distinct orders per period. The writ petitions were disposed of, quashing the composite orders and permitting respondents to initiate fresh proceedings confined to each assessment year separately.
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