Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Inspection-based satisfaction was sufficient to invoke extended limitation for tax short-payment, because the notices arose from records showing discrepancies between Form 26AS and GSTR-7 and expressly referred to wilful suppression; the initiation under Section 74 was therefore upheld. At the same time, the Court found that the revenue abstract and order had erroneously treated exempted turnover as tax liability for one period and referred to the wrong period in another, so both writ petitions were remitted for fresh adjudication on merits after personal hearing and detailed replies with supporting documents.
Inspection-based satisfaction was sufficient to invoke extended limitation for tax short-payment, because the notices arose from records showing discrepancies between Form 26AS and GSTR-7 and expressly referred to wilful suppression; the initiation under Section 74 was therefore upheld. At the same time, the Court found that the revenue abstract and order had erroneously treated exempted turnover as tax liability for one period and referred to the wrong period in another, so both writ petitions were remitted for fresh adjudication on merits after personal hearing and detailed replies with supporting documents.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
