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...
Absence of a Document Identification Number rendered the assessment orders invalid, as the High Court followed its earlier view that DIN is an inherent requirement for such orders. Although delay in filing the writ petitions was objected to on the basis of portal service, the Court entertained the delayed petitions in light of practical difficulties under the online GST regime, subject to deposit of 20% of the disputed tax. The impugned orders were set aside and the matter was remanded for fresh assessment after granting due opportunity of hearing, with adjustment of amounts already paid or recovered and exclusion of the intervening period for limitation.
Absence of a Document Identification Number rendered the assessment orders invalid, as the High Court followed its earlier view that DIN is an inherent requirement for such orders. Although delay in filing the writ petitions was objected to on the basis of portal service, the Court entertained the delayed petitions in light of practical difficulties under the online GST regime, subject to deposit of 20% of the disputed tax. The impugned orders were set aside and the matter was remanded for fresh assessment after granting due opportunity of hearing, with adjustment of amounts already paid or recovered and exclusion of the intervening period for limitation.
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