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...
An assessment order issued under the GST regime without a Document Identification Number was treated as non-est and unsustainable, following the principle that a DIN is mandatory for validity. The Court also held that a writ petition challenging the original assessment remained maintainable even though the statutory appeal had been dismissed as time-barred, since the challenge was directed to the invalidity of the foundational order. The assessment order was set aside and the matter remanded to the Assessing Officer for fresh consideration in accordance with law, with exclusion of the intervening period for limitation purposes.
An assessment order issued under the GST regime without a Document Identification Number was treated as non-est and unsustainable, following the principle that a DIN is mandatory for validity. The Court also held that a writ petition challenging the original assessment remained maintainable even though the statutory appeal had been dismissed as time-barred, since the challenge was directed to the invalidity of the foundational order. The assessment order was set aside and the matter remanded to the Assessing Officer for fresh consideration in accordance with law, with exclusion of the intervening period for limitation purposes.
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