Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Evasion of tax - mismatch in the e-way bill and the branch transfer invoice - levy of penalty and tax on the petitioner - The High Court observed that, even if there was discrepancy in the date which had occurred in the e-way bill as well as branch transfer invoice, there was no element of evasion of tax nor could any situation be pointed out to this Court where merely because of the said discrepancy, the petitioner could have evaded tax. - The HC set aside the imposing penalty and tax on the petitioner for the stock transfer between branches.
Evasion of tax - mismatch in the e-way bill and the branch transfer invoice - levy of penalty and tax on the petitioner - The High Court observed that, even if there was discrepancy in the date which had occurred in the e-way bill as well as branch transfer invoice, there was no element of evasion of tax nor could any situation be pointed out to this Court where merely because of the said discrepancy, the petitioner could have evaded tax. - The HC set aside the imposing penalty and tax on the petitioner for the stock transfer between branches.
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