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...
The HC disposed of the petitioner's challenge to an assessment order after the petitioner discharged tax liability and interest under an amnesty scheme settlement. The court balanced revenue and petitioner interests by remitting the matter to the first respondent for reconsideration of the penalty imposition under Section 74 of the GST enactment only. While the petitioner had settled the primary tax liability and interest components through the amnesty scheme, the court directed fresh consideration specifically regarding the penalty component, effectively providing partial relief to the petitioner while protecting revenue interests in the underlying tax assessment.
The HC disposed of the petitioner's challenge to an assessment order after the petitioner discharged tax liability and interest under an amnesty scheme settlement. The court balanced revenue and petitioner interests by remitting the matter to the first respondent for reconsideration of the penalty imposition under Section 74 of the GST enactment only. While the petitioner had settled the primary tax liability and interest components through the amnesty scheme, the court directed fresh consideration specifically regarding the penalty component, effectively providing partial relief to the petitioner while protecting revenue interests in the underlying tax assessment.
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