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 held that mentioning SAP document number instead of tax invoice number in e-way bill during transport from Mathura to Mirzapur was a genuine human error. Physical verification revealed no discrepancies in quality, quantity, or goods description between tax invoice and actual shipment. Authorities failed to establish any intention of tax evasion, which is essential for penalty imposition under Section 129 of GST Act. The technical mismatch alone cannot justify penalty proceedings when substantive compliance is evident. The court found impugned orders unsustainable, emphasizing that mere clerical errors, absent fraudulent intent, do not warrant punitive action. Petition allowed, setting aside tax and penalty orders.
HC held that mentioning SAP document number instead of tax invoice number in e-way bill during transport from Mathura to Mirzapur was a genuine human error. Physical verification revealed no discrepancies in quality, quantity, or goods description between tax invoice and actual shipment. Authorities failed to establish any intention of tax evasion, which is essential for penalty imposition under Section 129 of GST Act. The technical mismatch alone cannot justify penalty proceedings when substantive compliance is evident. The court found impugned orders unsustainable, emphasizing that mere clerical errors, absent fraudulent intent, do not warrant punitive action. Petition allowed, setting aside tax and penalty orders.
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