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 held that when excess stock is discovered during a survey under GST Act section 67, proceedings must be initiated under sections 73/74, not section 130. The statutory framework mandates that if a registered dealer fails to account for goods, the Proper Officer shall determine tax liability through sections 73/74. The court emphasized that GST Act is a comprehensive code, and section 130 cannot be invoked when specific provisions exist for addressing undeclared stock. The petitioner's challenge to proceedings was consequently allowed, establishing a clear legal principle that excess stock discovery triggers assessment proceedings rather than punitive actions.
HC held that when excess stock is discovered during a survey under GST Act section 67, proceedings must be initiated under sections 73/74, not section 130. The statutory framework mandates that if a registered dealer fails to account for goods, the Proper Officer shall determine tax liability through sections 73/74. The court emphasized that GST Act is a comprehensive code, and section 130 cannot be invoked when specific provisions exist for addressing undeclared stock. The petitioner's challenge to proceedings was consequently allowed, establishing a clear legal principle that excess stock discovery triggers assessment proceedings rather than punitive actions.
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