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 respondent resorted to profiteering by not passing on the benefit of GST rate reduction on cinema tickets, realizing an additional Rs. 4,65,549 from recipients. As per Rule 133, the respondent is directed to reduce ticket prices commensurate with the tax cut, deposit the profiteered amount of Rs. 4,65,549 plus 18% interest equally in central and state consumer welfare funds within 3 months. The respondent violated Section 171(1) by denying rate cut benefit, but penalty u/s 171(3A) cannot be imposed retrospectively. The jurisdictional GST commissioners are directed to monitor compliance and report to the commission within 4 months.
The respondent resorted to profiteering by not passing on the benefit of GST rate reduction on cinema tickets, realizing an additional Rs. 4,65,549 from recipients. As per Rule 133, the respondent is directed to reduce ticket prices commensurate with the tax cut, deposit the profiteered amount of Rs. 4,65,549 plus 18% interest equally in central and state consumer welfare funds within 3 months. The respondent violated Section 171(1) by denying rate cut benefit, but penalty u/s 171(3A) cannot be imposed retrospectively. The jurisdictional GST commissioners are directed to monitor compliance and report to the commission within 4 months.
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