Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
The HC held that the impugned transfer pricing adjustment was applied to the petitioner's entire turnover/operating costs rather than being confined to international/related-party transactions, which is contrary to settled law. The petitioner may press all available submissions before the CIT(A) in the pending statutory appeal; the CIT(A) is directed to decide the appeal expeditiously, preferably within 12 months. Pending disposal of the appeal and for four weeks thereafter, the Revenue is restrained from recovering taxes and interest attributable to the excess transfer pricing adjustment (≈ Rs.11,55,90,71,049 or as correctly computed) and from taking further proceedings on that specific issue. Stay applications on other additions to be decided by the Principal Commissioner in accordance with law.
The HC held that the impugned transfer pricing adjustment was applied to the petitioner's entire turnover/operating costs rather than being confined to international/related-party transactions, which is contrary to settled law. The petitioner may press all available submissions before the CIT(A) in the pending statutory appeal; the CIT(A) is directed to decide the appeal expeditiously, preferably within 12 months. Pending disposal of the appeal and for four weeks thereafter, the Revenue is restrained from recovering taxes and interest attributable to the excess transfer pricing adjustment (≈ Rs.11,55,90,71,049 or as correctly computed) and from taking further proceedings on that specific issue. Stay applications on other additions to be decided by the Principal Commissioner in accordance with law.
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