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 held the demand confirmed where the petitioner failed to reply to the Notice in Form GST DRC-01 and rejected the rectification application under Section 161 as time-barred and meritless, finding no procedural infirmity in the assessment order. The writ petition was dismissed as filed long after the statutory period for appeal had lapsed. The HC granted limited relief by permitting the petitioner liberty to file the statutory appellate remedy within 30 days from receipt of the order, subject to deposit of 50% of the disputed tax in cash; upon compliance the Deputy Commissioner (GST Appeals) shall entertain and dispose of the appeal notwithstanding limitation. Petition disposed.
HC held the demand confirmed where the petitioner failed to reply to the Notice in Form GST DRC-01 and rejected the rectification application under Section 161 as time-barred and meritless, finding no procedural infirmity in the assessment order. The writ petition was dismissed as filed long after the statutory period for appeal had lapsed. The HC granted limited relief by permitting the petitioner liberty to file the statutory appellate remedy within 30 days from receipt of the order, subject to deposit of 50% of the disputed tax in cash; upon compliance the Deputy Commissioner (GST Appeals) shall entertain and dispose of the appeal notwithstanding limitation. Petition disposed.
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