Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Section 74 CGST extended limitation applies only where available material permits a rational prima facie view that tax shortfall, erroneous refund or wrongful input tax credit arose by reason of fraud, wilful misstatement or suppression of facts to evade tax. Conclusive proof is not required at notice stage, but suspicion or a bare allegation is insufficient. Prior scrutiny, audit, inspection or pre-notice communications may supply the factual basis for a DRC-01 notice if they gave the taxpayer meaningful notice. Section 75 prevents confirmation on new grounds and permits treatment under the ordinary regime where the extended-period allegations are ultimately not established.
Section 74 CGST extended limitation applies only where available material permits a rational prima facie view that tax shortfall, erroneous refund or wrongful input tax credit arose by reason of fraud, wilful misstatement or suppression of facts to evade tax. Conclusive proof is not required at notice stage, but suspicion or a bare allegation is insufficient. Prior scrutiny, audit, inspection or pre-notice communications may supply the factual basis for a DRC-01 notice if they gave the taxpayer meaningful notice. Section 75 prevents confirmation on new grounds and permits treatment under the ordinary regime where the extended-period allegations are ultimately not established.
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