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...
The High Court quashed penalty u/s E-Way Bill violation, classifying goods as ODC due to speed without intent to evade tax. Relying on precedent, mens rea is essential for penalty. Transit speed not valid for penalty per circular. Speculative reasoning for penalties unfair. Penalties deter fraud, ensure compliance. Without intent, penalties unjust. Penalty imposition must be based on evidence of misconduct. Orders quashed, petition allowed.
The High Court quashed penalty u/s E-Way Bill violation, classifying goods as ODC due to speed without intent to evade tax. Relying on precedent, mens rea is essential for penalty. Transit speed not valid for penalty per circular. Speculative reasoning for penalties unfair. Penalties deter fraud, ensure compliance. Without intent, penalties unjust. Penalty imposition must be based on evidence of misconduct. Orders quashed, petition allowed.
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