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 court held that considering the petitioner has remitted the entire taxes and penalty, and was unable to present objections, the petitioner should be granted one final opportunity to appear before the respondent on 30.08.2024 along with objections and relevant documents. The impugned order dated 05.06.2023 passed by the respondent u/s 74 of the TNGST Act, 2017 regarding the mismatch between GSTR-1 and GSTR-3B is set aside. The petition is allowed.
The court held that considering the petitioner has remitted the entire taxes and penalty, and was unable to present objections, the petitioner should be granted one final opportunity to appear before the respondent on 30.08.2024 along with objections and relevant documents. The impugned order dated 05.06.2023 passed by the respondent u/s 74 of the TNGST Act, 2017 regarding the mismatch between GSTR-1 and GSTR-3B is set aside. The petition is allowed.
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