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...
Excess input tax credit relating to invoices for FY 2018-19 to 2020-21 was treated as validly reversed through debit entries in the electronic cash and credit ledgers reported in Form GST DRC-03. Absence of reasons in column 8 did not invalidate the reversal, as that field was not mandatory; Form GST DRC-04 acknowledged payment and the reconciliation statement supported full reversal. Section 16(5) extended the relevant ITC entitlement. For a Section 73 demand within Section 128A, interest and penalty require fresh computation after hearing, with waiver available subject to the prescribed procedure.
Excess input tax credit relating to invoices for FY 2018-19 to 2020-21 was treated as validly reversed through debit entries in the electronic cash and credit ledgers reported in Form GST DRC-03. Absence of reasons in column 8 did not invalidate the reversal, as that field was not mandatory; Form GST DRC-04 acknowledged payment and the reconciliation statement supported full reversal. Section 16(5) extended the relevant ITC entitlement. For a Section 73 demand within Section 128A, interest and penalty require fresh computation after hearing, with waiver available subject to the prescribed procedure.
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