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...
Late fee is leviable for failure to furnish the annual return by the due date, not only for belated filing after eventual submission; on that construction, non-filing of Form GSTR-9 attracts liability under the late-fee provision up to the prescribed cap. Where no separate penalty is prescribed for failure to file the annual return, the general penalty provision may still be invoked, and the existence of late-fee liability does not bar that recourse. The High Court upheld both the late fee and the penalty and dismissed the writ petition.
Late fee is leviable for failure to furnish the annual return by the due date, not only for belated filing after eventual submission; on that construction, non-filing of Form GSTR-9 attracts liability under the late-fee provision up to the prescribed cap. Where no separate penalty is prescribed for failure to file the annual return, the general penalty provision may still be invoked, and the existence of late-fee liability does not bar that recourse. The High Court upheld both the late fee and the penalty and dismissed the writ petition.
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