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...
HC held that confiscatory proceedings under the GST enactment cannot be invoked where the sole basis is excess stock found during survey. Because the impugned orders fastened tax liability and imposed penalty on that foundation alone, they were beyond the jurisdiction conferred by law and contrary to the settled legal position. The Court therefore set aside the orders and allowed the writ petition.
HC held that confiscatory proceedings under the GST enactment cannot be invoked where the sole basis is excess stock found during survey. Because the impugned orders fastened tax liability and imposed penalty on that foundation alone, they were beyond the jurisdiction conferred by law and contrary to the settled legal position. The Court therefore set aside the orders and allowed the writ petition.
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