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...
Sections 73 and 74 of the CGST Act do not bar a common or consolidated show cause notice for more than one tax period or financial year. The Court held that the references to "any period" and the limitation provisions do not confine notice issuance to a single financial year, while each component of a consolidated notice must still independently satisfy the applicable limitation test. It also rejected the objection based on pecuniary jurisdiction of the proper officer. Where Orders-in-Original were challenged, the Court restored the statutory position and granted time to file appeals, with limitation objections not to be raised if appeals were filed within the period allowed.
Sections 73 and 74 of the CGST Act do not bar a common or consolidated show cause notice for more than one tax period or financial year. The Court held that the references to "any period" and the limitation provisions do not confine notice issuance to a single financial year, while each component of a consolidated notice must still independently satisfy the applicable limitation test. It also rejected the objection based on pecuniary jurisdiction of the proper officer. Where Orders-in-Original were challenged, the Court restored the statutory position and granted time to file appeals, with limitation objections not to be raised if appeals were filed within the period allowed.
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