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...
HC dismissed the writ petition as not maintainable insofar as an alternative statutory remedy exists and the impugned order is appealable under Section 107. The court noted material suggesting the petitioner's GST registration was recent and that the entity may have been constituted to fraudulently avail ineligible input tax credit via fake, non-existent suppliers; business operations ceased following the petitioner's arrest. The petitioner's reply to the show-cause notice was found unpersuasive. Although the petition was filed within the limitation period, the period for appeal has lapsed; accordingly the HC permitted the petitioner to institute the statutory appeal by 15 December 2025 subject to depositing the requisite pre-deposit, and disposed of the petition.
HC dismissed the writ petition as not maintainable insofar as an alternative statutory remedy exists and the impugned order is appealable under Section 107. The court noted material suggesting the petitioner's GST registration was recent and that the entity may have been constituted to fraudulently avail ineligible input tax credit via fake, non-existent suppliers; business operations ceased following the petitioner's arrest. The petitioner's reply to the show-cause notice was found unpersuasive. Although the petition was filed within the limitation period, the period for appeal has lapsed; accordingly the HC permitted the petitioner to institute the statutory appeal by 15 December 2025 subject to depositing the requisite pre-deposit, and disposed of the petition.
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