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 addressed penalty u/s 129(3) of the Uttar Pradesh Goods and Services Tax Act, 2017 following premises search. Relying on precedent, the Court held that penalty proceedings post a search are not warranted. Quashed impugned orders of March 21, 2018 and August 31, 2018, finding them unjustified. Petition allowed based on lack of justification for penalty u/s 129 post-search.
The High Court addressed penalty u/s 129(3) of the Uttar Pradesh Goods and Services Tax Act, 2017 following premises search. Relying on precedent, the Court held that penalty proceedings post a search are not warranted. Quashed impugned orders of March 21, 2018 and August 31, 2018, finding them unjustified. Petition allowed based on lack of justification for penalty u/s 129 post-search.
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