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...
HC upheld provisional attachment orders under Section 83 of Gujarat GST Act 2017 against petitioner's bank accounts. Evidence revealed petitioner's involvement in issuing fraudulent bills and wrongful input tax credit claims, with estimated liability of Rs.12.33 crores. Court found legitimate grounds for attachment renewal after initial one-year period, distinguishing from RHC Global Exports precedent. Petitioner's modus operandi involved selling high-value goods without invoices while claiming ITC on lower-value items. Court determined no breach of Section 83, as attachment served to protect revenue interests during ongoing investigation involving ITC fraud exceeding Rs.18.97 crores. Petition dismissed, allowing continued attachment of bank accounts.
HC upheld provisional attachment orders under Section 83 of Gujarat GST Act 2017 against petitioner's bank accounts. Evidence revealed petitioner's involvement in issuing fraudulent bills and wrongful input tax credit claims, with estimated liability of Rs.12.33 crores. Court found legitimate grounds for attachment renewal after initial one-year period, distinguishing from RHC Global Exports precedent. Petitioner's modus operandi involved selling high-value goods without invoices while claiming ITC on lower-value items. Court determined no breach of Section 83, as attachment served to protect revenue interests during ongoing investigation involving ITC fraud exceeding Rs.18.97 crores. Petition dismissed, allowing continued attachment of bank accounts.
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