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...
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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