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 the imposition of penalty under Section 122(2)(b) of the GST Act, 2017 was procedurally flawed due to non-compliance with Rule 142(1A) regarding communication of tax details. The court found the tax liability determination for July 2017 to March 2019 legally erroneous. As an interim measure, the court directed the petitioner to deposit 20% of the tax amount determined in the original order within two weeks, with a consequent restraint on coercive recovery measures by the tax authorities pending further adjudication.
HC determined that the imposition of penalty under Section 122(2)(b) of the GST Act, 2017 was procedurally flawed due to non-compliance with Rule 142(1A) regarding communication of tax details. The court found the tax liability determination for July 2017 to March 2019 legally erroneous. As an interim measure, the court directed the petitioner to deposit 20% of the tax amount determined in the original order within two weeks, with a consequent restraint on coercive recovery measures by the tax authorities pending further adjudication.
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