Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Scrutiny-based show cause notices for unreconciled input tax credit were treated as distinct from earlier audit-based proceedings, and the overlap with the prior section 73 action could not be resolved at the notice stage without a reply. The court held that, where the record suggests possible non-payment or short payment by reason of fraud, wilful misstatement or suppression, a section 74 notice may be issued. The challenge was therefore not entertained at issuance, and the taxpayer was directed to respond before final adjudication.
Scrutiny-based show cause notices for unreconciled input tax credit were treated as distinct from earlier audit-based proceedings, and the overlap with the prior section 73 action could not be resolved at the notice stage without a reply. The court held that, where the record suggests possible non-payment or short payment by reason of fraud, wilful misstatement or suppression, a section 74 notice may be issued. The challenge was therefore not entertained at issuance, and the taxpayer was directed to respond before final adjudication.
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