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 for violation of section 129 and Rule 138 - Failure to update the E-way bill on change of vehicle after breakdown - The imposition of penalties for mere technical errors in tax law, without evidence of intent to evade tax, is not sustainable. The court emphasized that penalties should only be imposed when there's a deliberate intent to evade taxes, differentiating between inadvertent technical errors and purposeful attempts to circumvent tax obligations. - HC
Levy of penalty for violation of section 129 and Rule 138 - Failure to update the E-way bill on change of vehicle after breakdown - The imposition of penalties for mere technical errors in tax law, without evidence of intent to evade tax, is not sustainable. The court emphasized that penalties should only be imposed when there's a deliberate intent to evade taxes, differentiating between inadvertent technical errors and purposeful attempts to circumvent tax obligations. - HC
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