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...
Respondent resorted to profiteering by not reducing selling price commensurately despite GST rate reduction from 28% to 18% on cinema tickets above Rs. 100, from 01.01.2019 to 05.02.2019, profiteering Rs. 13,99,061 including GST. Respondent directed to reduce prices keeping rate reduction in view, having revised ticket price from Rs. 150 to Rs. 138 from 06.02.2019 depicting commensurate benefit passing. Respondent denied rate reduction benefit to customers violating Section 171(1) of CGST Act, 2017, committing offence u/s 171(3A) inserted from 01.01.2020, hence penalty u/s 171(3A) cannot be imposed retrospectively for said period.
Respondent resorted to profiteering by not reducing selling price commensurately despite GST rate reduction from 28% to 18% on cinema tickets above Rs. 100, from 01.01.2019 to 05.02.2019, profiteering Rs. 13,99,061 including GST. Respondent directed to reduce prices keeping rate reduction in view, having revised ticket price from Rs. 150 to Rs. 138 from 06.02.2019 depicting commensurate benefit passing. Respondent denied rate reduction benefit to customers violating Section 171(1) of CGST Act, 2017, committing offence u/s 171(3A) inserted from 01.01.2020, hence penalty u/s 171(3A) cannot be imposed retrospectively for said period.
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