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...
Section 74 of the CGST Act requires evidence of fraud, willful misstatement or deliberate suppression with intent to evade tax; mere availment of ineligible self-assessed input tax credit does not meet that standard. Disclosure of ITC reconciliation in GSTR-9C and annual returns on the GST portal negates an allegation of concealed facts absent contrary evidence. Failure to reply to an audit enquiry or final audit report is likewise not suppression where the underlying data is disclosed and no statutory reply is required. A demand also cannot be sustained on a ground introduced beyond the show cause notice, as this denies the taxpayer an opportunity to respond and breaches natural justice.
Section 74 of the CGST Act requires evidence of fraud, willful misstatement or deliberate suppression with intent to evade tax; mere availment of ineligible self-assessed input tax credit does not meet that standard. Disclosure of ITC reconciliation in GSTR-9C and annual returns on the GST portal negates an allegation of concealed facts absent contrary evidence. Failure to reply to an audit enquiry or final audit report is likewise not suppression where the underlying data is disclosed and no statutory reply is required. A demand also cannot be sustained on a ground introduced beyond the show cause notice, as this denies the taxpayer an opportunity to respond and breaches natural justice.
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