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...
Article 226 writ jurisdiction should not ordinarily supplant an efficacious statutory appeal where the petitioner, by fault, disabled itself from filing the statutory remedy; failure to show sufficient cause for delay in instituting the appeal justified refusal to exercise discretionary writ relief. The adjudication cancelling GST registration was not set aside for breach of natural justice because show cause notices and opportunities to be heard were issued and the petitioner neither responded nor demonstrated non service; a bare allegation of ex parte decision contradicted the record. Petition dismissed for failure to bypass the alternate statutory remedy and to establish procedural unfairness.
Article 226 writ jurisdiction should not ordinarily supplant an efficacious statutory appeal where the petitioner, by fault, disabled itself from filing the statutory remedy; failure to show sufficient cause for delay in instituting the appeal justified refusal to exercise discretionary writ relief. The adjudication cancelling GST registration was not set aside for breach of natural justice because show cause notices and opportunities to be heard were issued and the petitioner neither responded nor demonstrated non service; a bare allegation of ex parte decision contradicted the record. Petition dismissed for failure to bypass the alternate statutory remedy and to establish procedural unfairness.
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