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...
Provisional attachment of bank account u/s 83 of Central Goods and Services Tax Act, 2017 for wrongful claim of Input Tax Credit (ITC) due to fake supplies. Commissioner considered appropriate to provisionally attach petitioner's bank account to extent of Rs. 26.91 lacs being amount of ITC claimed for allegedly fake supplies. Exercise of power by Commissioner warranted as facts indicate necessity to provisionally attach petitioner's bank account to protect revenue interest. Material available with Commissioner has live nexus with his opinion. Impugned order cannot be faulted. Petition dismissed as unmerited.
Provisional attachment of bank account u/s 83 of Central Goods and Services Tax Act, 2017 for wrongful claim of Input Tax Credit (ITC) due to fake supplies. Commissioner considered appropriate to provisionally attach petitioner's bank account to extent of Rs. 26.91 lacs being amount of ITC claimed for allegedly fake supplies. Exercise of power by Commissioner warranted as facts indicate necessity to provisionally attach petitioner's bank account to protect revenue interest. Material available with Commissioner has live nexus with his opinion. Impugned order cannot be faulted. Petition dismissed as unmerited.
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