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...
Section 128A permits waiver of interest and penalty where proceedings under Section 73 determine unpaid or short-paid self-assessed tax; direct recovery under Section 79 without Section 73 proceedings does not support a waiver application. Circular No. 238 cannot narrow that statutory scope. Rule 164 limits voidness of an approved waiver in Form GST SPL-05 or GST SPL-06 to specified failures to make additional payment; authorities lack power to issue void orders outside those circumstances. Rule 164 creates mandatory filing and disposal timelines. Failure to decide within the prescribed period may result in deemed approval, subject to fulfilment of Section 128A, whereas late applications or late payment cannot be cured through substantial compliance.
Section 128A permits waiver of interest and penalty where proceedings under Section 73 determine unpaid or short-paid self-assessed tax; direct recovery under Section 79 without Section 73 proceedings does not support a waiver application. Circular No. 238 cannot narrow that statutory scope. Rule 164 limits voidness of an approved waiver in Form GST SPL-05 or GST SPL-06 to specified failures to make additional payment; authorities lack power to issue void orders outside those circumstances. Rule 164 creates mandatory filing and disposal timelines. Failure to decide within the prescribed period may result in deemed approval, subject to fulfilment of Section 128A, whereas late applications or late payment cannot be cured through substantial compliance.
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