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 granted relief to the Petitioner, directing the tax authority to comply with statutory obligations under the CGST Act regarding seizure, copying and return of electronic devices and documents. The court held that inspection, search and seizure powers rest with the revenue, but materials not relied upon must be returned within 30 days and copies of seized data must be furnished to the Petitioner unless a written record shows prejudice to investigation. Finding that data extraction and cloning had largely been completed, the HC ordered the proprietor of the Petitioner to appear in person before an Authorised Officer to receive copies of the entire dataset and documents. The petition was disposed of accordingly.
The HC granted relief to the Petitioner, directing the tax authority to comply with statutory obligations under the CGST Act regarding seizure, copying and return of electronic devices and documents. The court held that inspection, search and seizure powers rest with the revenue, but materials not relied upon must be returned within 30 days and copies of seized data must be furnished to the Petitioner unless a written record shows prejudice to investigation. Finding that data extraction and cloning had largely been completed, the HC ordered the proprietor of the Petitioner to appear in person before an Authorised Officer to receive copies of the entire dataset and documents. The petition was disposed of accordingly.
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