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...
Cancellation of GST registration was upheld where registration was obtained to wrongfully avail input tax credit without proof of physical movement and genuineness; court found transactions were camouflaged by mantenering multiple registrations at the same premises, and that invoices were used to pass illegitimate ITC. The appellate order affirming cancellation was not interfered with for lack of justification in holding separate registrations for the same premises; consequence: the writ petition dismissed and respondents granted liberty to recover tax and penalty from customers.
Cancellation of GST registration was upheld where registration was obtained to wrongfully avail input tax credit without proof of physical movement and genuineness; court found transactions were camouflaged by mantenering multiple registrations at the same premises, and that invoices were used to pass illegitimate ITC. The appellate order affirming cancellation was not interfered with for lack of justification in holding separate registrations for the same premises; consequence: the writ petition dismissed and respondents granted liberty to recover tax and penalty from customers.
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