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...
Statutory appeals were rejected as time-barred because the delay exceeded the condonable period, and the High Court found no legal basis to interfere with that appellate rejection. The dispute concerned GST assessment orders arising from return mismatches, with intimations already issued, so no further interference was warranted on that record. However, on the petitioners' express consent, the Court directed fresh adjudication on merits after payment of the balance disputed tax or required disputed tax, as applicable, and filing replies with supporting documents; the impugned orders were treated as addenda to the show cause notices. Any bank attachment was to stand vacated only upon compliance with those conditions.
Statutory appeals were rejected as time-barred because the delay exceeded the condonable period, and the High Court found no legal basis to interfere with that appellate rejection. The dispute concerned GST assessment orders arising from return mismatches, with intimations already issued, so no further interference was warranted on that record. However, on the petitioners' express consent, the Court directed fresh adjudication on merits after payment of the balance disputed tax or required disputed tax, as applicable, and filing replies with supporting documents; the impugned orders were treated as addenda to the show cause notices. Any bank attachment was to stand vacated only upon compliance with those conditions.
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