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...
Penalty u/s 129(1)(b) - Part-B of the e-way bill was not filled up - The High Court held that, upon a perusal of the order in appeal, it is crystal clear that the petitioner could not justify the reasons for non production of the invoice and the e-way bill. In such cases, a presumption automatically arises that there was an intention to evade tax. This presumption would be rebuttable. However, the petitioner was not able to bring any evidence to rebut the said presumption of evasion of tax.
Penalty u/s 129(1)(b) - Part-B of the e-way bill was not filled up - The High Court held that, upon a perusal of the order in appeal, it is crystal clear that the petitioner could not justify the reasons for non production of the invoice and the e-way bill. In such cases, a presumption automatically arises that there was an intention to evade tax. This presumption would be rebuttable. However, the petitioner was not able to bring any evidence to rebut the said presumption of evasion of tax.
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