Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Section 74 GST action was upheld because the show cause notice and assessment were based on a prima facie discrepancy between the seigniorage fee-linked quantity/value and the lower value disclosed in returns, amounting to alleged suppression of outward supply. The HC held that this was sufficient foundational material for invoking the extended period of limitation, and rejected the challenge that there was no basis for Section 74 proceedings. The natural justice objection also failed because intimation notices and show cause notices had been issued and replies were filed, leaving no procedural defect warranting writ interference. The writ petitions were dismissed, with liberty to pursue the statutory appeal.
Section 74 GST action was upheld because the show cause notice and assessment were based on a prima facie discrepancy between the seigniorage fee-linked quantity/value and the lower value disclosed in returns, amounting to alleged suppression of outward supply. The HC held that this was sufficient foundational material for invoking the extended period of limitation, and rejected the challenge that there was no basis for Section 74 proceedings. The natural justice objection also failed because intimation notices and show cause notices had been issued and replies were filed, leaving no procedural defect warranting writ interference. The writ petitions were dismissed, with liberty to pursue the statutory appeal.
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