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 declined to entertain the writ, finding matters of alleged fraudulent availment of input tax credit ordinarily unsuitable for writ jurisdiction where complex factual and evidentiary inquiries and the protection of the public exchequer require exhaustion of statutory remedies. The Court held the Petitioner had received notices and filed responses, raised no substantive merits other than non-supply of RUDs, and was relegated to the statutory appellate route under s.107, CGST. The Petitioner is directed to file the appeal with the requisite pre-deposit by 30 November 2025; if so filed, the appeal will be admitted and not dismissed as time-barred. Petition disposed.
The HC declined to entertain the writ, finding matters of alleged fraudulent availment of input tax credit ordinarily unsuitable for writ jurisdiction where complex factual and evidentiary inquiries and the protection of the public exchequer require exhaustion of statutory remedies. The Court held the Petitioner had received notices and filed responses, raised no substantive merits other than non-supply of RUDs, and was relegated to the statutory appellate route under s.107, CGST. The Petitioner is directed to file the appeal with the requisite pre-deposit by 30 November 2025; if so filed, the appeal will be admitted and not dismissed as time-barred. Petition disposed.
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