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...
GST recovery stay pending Tribunal proceedings was available only on compliance with the prescribed pre-deposit and filing an undertaking to appeal within time; where the taxpayer did not follow that procedure and sought refund after recovery had already been made, refund was refused. The taxpayer's plea of ignorance of the circular was rejected on the principle that ignorance of law is no excuse. Granting refund would have operated as an impermissible waiver of the pre-deposit, while the Tribunal was left free to decide the appeal on merits.
GST recovery stay pending Tribunal proceedings was available only on compliance with the prescribed pre-deposit and filing an undertaking to appeal within time; where the taxpayer did not follow that procedure and sought refund after recovery had already been made, refund was refused. The taxpayer's plea of ignorance of the circular was rejected on the principle that ignorance of law is no excuse. Granting refund would have operated as an impermissible waiver of the pre-deposit, while the Tribunal was left free to decide the appeal on merits.
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