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 Instruction issued by the Government of India (CBIC) provides guidelines for initiating recovery proceedings u/s 79 of the Central Goods and Services Tax Act, 2017 (GST Act). Recovery proceedings can be initiated if any amount payable by a taxable person is not paid within three months from the date of service of the order. However, in exceptional cases for the interest of revenue, the proper officer may require early payment with recorded reasons. The jurisdictional Deputy or Assistant Commissioner must seek approval from the Principal Commissioner/ Commissioner before initiating early recovery. Reasons for early recovery must be based on credible evidence to safeguard revenue. Failure to comply results in recovery as per u/s 79. Any difficulties in implementation should be reported to the Board.
The Instruction issued by the Government of India (CBIC) provides guidelines for initiating recovery proceedings u/s 79 of the Central Goods and Services Tax Act, 2017 (GST Act). Recovery proceedings can be initiated if any amount payable by a taxable person is not paid within three months from the date of service of the order. However, in exceptional cases for the interest of revenue, the proper officer may require early payment with recorded reasons. The jurisdictional Deputy or Assistant Commissioner must seek approval from the Principal Commissioner/ Commissioner before initiating early recovery. Reasons for early recovery must be based on credible evidence to safeguard revenue. Failure to comply results in recovery as per u/s 79. Any difficulties in implementation should be reported to the Board.
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