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 dismissed the writ insofar as it sought quashing of the impugned demand without compliance with limitation; noting the period for filing an appeal under Section 107 of the GST enactments had expired, the Court remitted the matter to the Respondent for fresh adjudication. The remand is conditional: the Assessee must deposit 50% of the disputed tax, quantified at 1,92,32,187, in cash from its Electronic Cash Ledger within 30 days of receipt of this order. On such deposit, the Respondent shall pass a fresh order after considering payments already made; otherwise the remand terms may be altered. The writ petition is disposed.
HC dismissed the writ insofar as it sought quashing of the impugned demand without compliance with limitation; noting the period for filing an appeal under Section 107 of the GST enactments had expired, the Court remitted the matter to the Respondent for fresh adjudication. The remand is conditional: the Assessee must deposit 50% of the disputed tax, quantified at 1,92,32,187, in cash from its Electronic Cash Ledger within 30 days of receipt of this order. On such deposit, the Respondent shall pass a fresh order after considering payments already made; otherwise the remand terms may be altered. The writ petition is disposed.
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