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...
Levy of penalty - goods were unloaded at a place that was not registered in the registration certificate - unloading goods at a location not specified in the e-way bill - The petitioner argues that the unloading occurred at their own registered godown, with no intent to evade tax. The court underscores the importance of establishing mens rea for penalty imposition, citing precedents. It distinguishes minor errors from major lapses and concludes that the minor typographical error in the e-way bill, coupled with the absence of intent to evade tax, renders the penalty unwarranted.
Levy of penalty - goods were unloaded at a place that was not registered in the registration certificate - unloading goods at a location not specified in the e-way bill - The petitioner argues that the unloading occurred at their own registered godown, with no intent to evade tax. The court underscores the importance of establishing mens rea for penalty imposition, citing precedents. It distinguishes minor errors from major lapses and concludes that the minor typographical error in the e-way bill, coupled with the absence of intent to evade tax, renders the penalty unwarranted.
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