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...
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.
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