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 dismissed the writ petition, holding the impugned adjudicatory order dated 27 January 2025 has become final due to the lapse of the statutory appeal period under Section 107 CGST; no sufficient explanation justified the delay in prosecuting the appeal. The court found no gross breach of natural justice: the Adjudicating Authority considered the petitioner's filed reply and documents, and acknowledgements evidenced filing though not incontrovertible proof of attendance. On the merits, the HC concluded the petitioner colluded with a third-party supplier to fraudulently avail ineligible ITC, failed to rebut the show-cause allegations or identify the supplier, and did not cooperate in proceedings. No exceptional circumstances warranted condonation of delay or exercise of writ jurisdiction.
The HC dismissed the writ petition, holding the impugned adjudicatory order dated 27 January 2025 has become final due to the lapse of the statutory appeal period under Section 107 CGST; no sufficient explanation justified the delay in prosecuting the appeal. The court found no gross breach of natural justice: the Adjudicating Authority considered the petitioner's filed reply and documents, and acknowledgements evidenced filing though not incontrovertible proof of attendance. On the merits, the HC concluded the petitioner colluded with a third-party supplier to fraudulently avail ineligible ITC, failed to rebut the show-cause allegations or identify the supplier, and did not cooperate in proceedings. No exceptional circumstances warranted condonation of delay or exercise of writ jurisdiction.
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