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...
Short payment of GST on unreconciled sales turnover - non-reversal of Input Tax Credit (ITC) - The assessing officer rejected the petitioner's explanation, citing lethargy in maintaining accounts. However, the High Court found that even if the petitioner was lax in rectifying the mistake promptly, it didn't justify the substantial tax liability imposed solely based on a reporting error. The Court noted that the statute didn't allow rectification until the annual return was filed, and therefore, the petitioner's actions were within legal bounds.
Short payment of GST on unreconciled sales turnover - non-reversal of Input Tax Credit (ITC) - The assessing officer rejected the petitioner's explanation, citing lethargy in maintaining accounts. However, the High Court found that even if the petitioner was lax in rectifying the mistake promptly, it didn't justify the substantial tax liability imposed solely based on a reporting error. The Court noted that the statute didn't allow rectification until the annual return was filed, and therefore, the petitioner's actions were within legal bounds.
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