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 set aside the impugned order of 26.08.2025, holding that the Adjudicating Authority erred in computing penalty under Section 129(1)(b) instead of Section 129(1)(a) of the U.P. GST Act, 2017; therefore the matter is remitted to the authorities to determine the quantum of penalty under Section 129(1)(a) within three weeks. The petitioner is directed to deposit the penalty calculated on the value of goods as declared in the tax invoice, whereupon the goods shall be released forthwith. The writ petition is disposed of by consent, with no further adjudication required pending compliance with the directions.
The HC set aside the impugned order of 26.08.2025, holding that the Adjudicating Authority erred in computing penalty under Section 129(1)(b) instead of Section 129(1)(a) of the U.P. GST Act, 2017; therefore the matter is remitted to the authorities to determine the quantum of penalty under Section 129(1)(a) within three weeks. The petitioner is directed to deposit the penalty calculated on the value of goods as declared in the tax invoice, whereupon the goods shall be released forthwith. The writ petition is disposed of by consent, with no further adjudication required pending compliance with the directions.
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