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 exercise writ jurisdiction in a challenge to alleged fraudulent availment of Input Tax Credit, holding the dispute raises factual questions (inspection at the petitioner's registered premise found the petitioner non-existent) more appropriately determined on appeal rather than by writ. The petition was therefore dismissed, but the petitioner was granted liberty to file an appeal by 30 November 2025 subject to making the requisite pre-deposit; the HC directed that the appeal, once filed with the pre-deposit, shall be entertained and adjudicated on merits and shall not be dismissed on the ground of limitation. Petition disposed.
The HC declined to exercise writ jurisdiction in a challenge to alleged fraudulent availment of Input Tax Credit, holding the dispute raises factual questions (inspection at the petitioner's registered premise found the petitioner non-existent) more appropriately determined on appeal rather than by writ. The petition was therefore dismissed, but the petitioner was granted liberty to file an appeal by 30 November 2025 subject to making the requisite pre-deposit; the HC directed that the appeal, once filed with the pre-deposit, shall be entertained and adjudicated on merits and shall not be dismissed on the ground of limitation. Petition disposed.
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