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 ruled that the petitioner, not being a 'supplier' under GST Act Section 2(105), was improperly penalized Rs.7,36,490/- for failing to generate Part-B of E-Way Bill during goods transportation for job work. The court found the penalty disproportionate, considering the petitioner had generated Part-A of E-Way Bill and provided a valid Delivery Challan. The impugned order was modified, reducing the penalty to Rs.25,000/- and directing respondents to refund the excess amount through Electronic Cash or Credit Ledger, thereby partly allowing the petition and rectifying the unjustified punitive action.
HC ruled that the petitioner, not being a 'supplier' under GST Act Section 2(105), was improperly penalized Rs.7,36,490/- for failing to generate Part-B of E-Way Bill during goods transportation for job work. The court found the penalty disproportionate, considering the petitioner had generated Part-A of E-Way Bill and provided a valid Delivery Challan. The impugned order was modified, reducing the penalty to Rs.25,000/- and directing respondents to refund the excess amount through Electronic Cash or Credit Ledger, thereby partly allowing the petition and rectifying the unjustified punitive action.
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