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 set aside the impugned demand notices under DRC-01 and held the reasoning insufficient to sustain a tax demand based solely on alleged suppression in GSTR-1, GSTR-3B and GSTR-9C; the respondents must first adduce cogent evidence of turnover suppression before issuing demand. The Court recognised that disproportionate inward versus outward supplies might stem from excess availing of Input Tax Credit, warranting further enquiry. The matter is remitted to the respondent for fresh adjudication; the petitioner is permitted to file a reply with supporting documents. Petition disposed of by remand with liberty to proceed in accordance with law.
The HC set aside the impugned demand notices under DRC-01 and held the reasoning insufficient to sustain a tax demand based solely on alleged suppression in GSTR-1, GSTR-3B and GSTR-9C; the respondents must first adduce cogent evidence of turnover suppression before issuing demand. The Court recognised that disproportionate inward versus outward supplies might stem from excess availing of Input Tax Credit, warranting further enquiry. The matter is remitted to the respondent for fresh adjudication; the petitioner is permitted to file a reply with supporting documents. Petition disposed of by remand with liberty to proceed in accordance with law.
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