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...
Levy of penalty u/s 26 of CER - supply of invoices without supply of capital goods - The investigation was conducted five years after the goods were supplied. Once the goods were supplied by the appellant, they are beyond its control. Inconsistency in the invoices ledger of the transporter also does not carry the case of the Revenue any further because transportation was the responsibility of the buyer and not of the appellant. - AT
Levy of penalty u/s 26 of CER - supply of invoices without supply of capital goods - The investigation was conducted five years after the goods were supplied. Once the goods were supplied by the appellant, they are beyond its control. Inconsistency in the invoices ledger of the transporter also does not carry the case of the Revenue any further because transportation was the responsibility of the buyer and not of the appellant. - AT
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