Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Entertainability of petition challenging show cause notice for recovery of taxes, determination of value of supply u/s 15(3)(b) of CGST Act. Allegations of suppressing facts, misstatement regarding non-furnishing outward supplies u/s 37, intention to evade GST from July 2017 to March 2022. Invocation of extended period of limitation based on suppression, misstatement with intent to evade GST. Adjudication on factual issues of suppression, misstatement, onus of proof u/s 15(3)(b) cannot be undertaken in writ jurisdiction. No challenge to circular in prayer. Petition dismissed, time granted till 15 December 2024 to file reply. Personal hearing, reasoned order by 31 January 2025 directed.
Entertainability of petition challenging show cause notice for recovery of taxes, determination of value of supply u/s 15(3)(b) of CGST Act. Allegations of suppressing facts, misstatement regarding non-furnishing outward supplies u/s 37, intention to evade GST from July 2017 to March 2022. Invocation of extended period of limitation based on suppression, misstatement with intent to evade GST. Adjudication on factual issues of suppression, misstatement, onus of proof u/s 15(3)(b) cannot be undertaken in writ jurisdiction. No challenge to circular in prayer. Petition dismissed, time granted till 15 December 2024 to file reply. Personal hearing, reasoned order by 31 January 2025 directed.
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