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 held Section 171 CGST Act, 2017 and the specified Rules raise substantive issues warranting re-examination and remanded the matter for fact-finding by the Principal Bench of the GSTAT as NAPA. Noting a cut-off of 01.04.2025 for acceptance of anti-profiteering requests, the Court found that, given the GST rate increase affecting the Petitioner, the Directorate General's investigation required scrutiny to determine whether findings of profiteering rested on evidence or mere conjecture. The impugned order dated 29.08.2022 was set aside and the petition was disposed of by remand for fresh hearing before the Principal Bench of GSTAT on 14.10.2025.
The HC held Section 171 CGST Act, 2017 and the specified Rules raise substantive issues warranting re-examination and remanded the matter for fact-finding by the Principal Bench of the GSTAT as NAPA. Noting a cut-off of 01.04.2025 for acceptance of anti-profiteering requests, the Court found that, given the GST rate increase affecting the Petitioner, the Directorate General's investigation required scrutiny to determine whether findings of profiteering rested on evidence or mere conjecture. The impugned order dated 29.08.2022 was set aside and the petition was disposed of by remand for fresh hearing before the Principal Bench of GSTAT on 14.10.2025.
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