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...
Petitioner availed fake input tax credit through bogus billing, generating fake sale invoices. Provisional attachment of movable properties in addition to immovable properties already attached was ordered u/s 83 to protect government revenue interest. Authority formed opinion based on material that petitioner's immovable properties were insufficient to cover likely demand exceeding Rs. 76 crore arising from fraudulent invoices and input tax credit utilization. No harassment found in provisional attachment of movable properties during pendency of investigation to safeguard revenue interest. Petition dismissed by High Court.
Petitioner availed fake input tax credit through bogus billing, generating fake sale invoices. Provisional attachment of movable properties in addition to immovable properties already attached was ordered u/s 83 to protect government revenue interest. Authority formed opinion based on material that petitioner's immovable properties were insufficient to cover likely demand exceeding Rs. 76 crore arising from fraudulent invoices and input tax credit utilization. No harassment found in provisional attachment of movable properties during pendency of investigation to safeguard revenue interest. Petition dismissed by High Court.
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