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...
Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.
Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.
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