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...
Detention of goods due to incomplete Part B of E-way bill. No dispute on documents/goods. Part B filled before notice/seizure order. No mens rea found to evade tax. Citing M/S ROLI ENTERPRISES case, technical error without tax evasion intent warrants no penalty u/s 129(3). Similar ruling in PRECISION TOOLS INDIA case. Orders dated April 22, 2021 and November 20, 2021 quashed by HC. Writ petition allowed.
Detention of goods due to incomplete Part B of E-way bill. No dispute on documents/goods. Part B filled before notice/seizure order. No mens rea found to evade tax. Citing M/S ROLI ENTERPRISES case, technical error without tax evasion intent warrants no penalty u/s 129(3). Similar ruling in PRECISION TOOLS INDIA case. Orders dated April 22, 2021 and November 20, 2021 quashed by HC. Writ petition allowed.
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