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 held that the petitioner, having subsequently filed requisite returns and paid assessed tax following issuance of best-judgment assessment orders under s.62(1) of the UPGST Act, benefited from the deeming fiction in s.62(2) so that further demands were required to be withdrawn. Creation of liens and freezing of the petitioner's bank accounts under s.79 more than a year after taxes were paid was held impermissible as applied in the circumstances and constituted an unduly harsh exercise of recovery powers; invocation of s.79 for recovery was therefore ultra vires as to these amounts. The petition was allowed and disposed of.
The HC held that the petitioner, having subsequently filed requisite returns and paid assessed tax following issuance of best-judgment assessment orders under s.62(1) of the UPGST Act, benefited from the deeming fiction in s.62(2) so that further demands were required to be withdrawn. Creation of liens and freezing of the petitioner's bank accounts under s.79 more than a year after taxes were paid was held impermissible as applied in the circumstances and constituted an unduly harsh exercise of recovery powers; invocation of s.79 for recovery was therefore ultra vires as to these amounts. The petition was allowed and disposed of.
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