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...
Extended period of limitation - The very fact that the appellant is contesting the issue of invoking larger period of limitation, that the rendering of service under the ‘supply of tangible goods’ is accepted; but for survey, persuasion, etc., by the officials, the tax would have remained unpaid amounting to evasion of duty. The other fact that the rendering of service and the receipt is not shown in the ST-3 return thus clearly amounts to suppression of facts; and hence, it is a clear case of suppression of facts with intent to evade tax payment. - Demand confirmed - AT
Extended period of limitation - The very fact that the appellant is contesting the issue of invoking larger period of limitation, that the rendering of service under the ‘supply of tangible goods’ is accepted; but for survey, persuasion, etc., by the officials, the tax would have remained unpaid amounting to evasion of duty. The other fact that the rendering of service and the receipt is not shown in the ST-3 return thus clearly amounts to suppression of facts; and hence, it is a clear case of suppression of facts with intent to evade tax payment. - Demand confirmed - AT
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