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...
A writ petition challenging GST search, seizure and adjudicatory action was declined because the petitioners had an efficacious statutory appeal and no exceptional ground for writ interference. The Court also found no prima facie merit in the objections to officer competence or adjudication by the officer concerned, noting the notification assigning powers to Central Tax Officers and the absence of any substantive merits challenge. A vires challenge to the impugned circulars was not entertained because such a challenge must be raised at the earliest and requires a strong prima facie case, which was not shown. The petitioners were left to pursue the appellate remedy, without any final adjudication on merits.
A writ petition challenging GST search, seizure and adjudicatory action was declined because the petitioners had an efficacious statutory appeal and no exceptional ground for writ interference. The Court also found no prima facie merit in the objections to officer competence or adjudication by the officer concerned, noting the notification assigning powers to Central Tax Officers and the absence of any substantive merits challenge. A vires challenge to the impugned circulars was not entertained because such a challenge must be raised at the earliest and requires a strong prima facie case, which was not shown. The petitioners were left to pursue the appellate remedy, without any final adjudication on merits.
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