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...
HC determined that detention of goods and penalties imposed for missing e-tax invoice were unjustified. While physical tax invoice, e-way bill, and bilty accompanied the goods with accurate descriptions and quantities, the e-tax invoice was absent due to technical issues with GST portal. The authorities failed to establish any intent to evade tax payments. The petitioner's explanation regarding technical glitch remained undisputed. Following precedents where deficiencies noted in show cause notices were rectified before detention orders, the court held that penalties were unwarranted when no tax evasion was proven. The impugned order was set aside and the petition was allowed, establishing that technical non-compliance without fraudulent intent does not merit punitive action.
HC determined that detention of goods and penalties imposed for missing e-tax invoice were unjustified. While physical tax invoice, e-way bill, and bilty accompanied the goods with accurate descriptions and quantities, the e-tax invoice was absent due to technical issues with GST portal. The authorities failed to establish any intent to evade tax payments. The petitioner's explanation regarding technical glitch remained undisputed. Following precedents where deficiencies noted in show cause notices were rectified before detention orders, the court held that penalties were unwarranted when no tax evasion was proven. The impugned order was set aside and the petition was allowed, establishing that technical non-compliance without fraudulent intent does not merit punitive action.
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