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...
Parallel Central GST adjudication could not be sustained where the same suppliers, the same alleged fake or non-existent status, and the same ITC disallowance for the same periods had already been adjudicated by the State GST Authority. Applying the principle against overlapping jurisdiction and duplicate proceedings on the same subject matter, the Court held that the later Central adjudication was unsustainable and set it aside. The Court declined to examine other issues and disposed of the connected applications accordingly.
Parallel Central GST adjudication could not be sustained where the same suppliers, the same alleged fake or non-existent status, and the same ITC disallowance for the same periods had already been adjudicated by the State GST Authority. Applying the principle against overlapping jurisdiction and duplicate proceedings on the same subject matter, the Court held that the later Central adjudication was unsustainable and set it aside. The Court declined to examine other issues and disposed of the connected applications accordingly.
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