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 allowed the petition, set aside the impugned order dated 06.01.2025 and remanded the matter to the AO for fresh proceedings in accordance with law. The court accepted that although an appeal had been initially rejected on limitation grounds, the validity of the underlying order was vitiated by non-inclusion of the DIN as required under the GST Act and related administrative instructions; consequently the impugned order is treated as invalid and requires fresh adjudication. The AO is directed to proceed afresh, ensuring statutory formalities (including DIN compliance) are observed and to decide the matter on merits within the statutory framework.
The HC allowed the petition, set aside the impugned order dated 06.01.2025 and remanded the matter to the AO for fresh proceedings in accordance with law. The court accepted that although an appeal had been initially rejected on limitation grounds, the validity of the underlying order was vitiated by non-inclusion of the DIN as required under the GST Act and related administrative instructions; consequently the impugned order is treated as invalid and requires fresh adjudication. The AO is directed to proceed afresh, ensuring statutory formalities (including DIN compliance) are observed and to decide the matter on merits within the statutory framework.
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