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 order dated 18.10.2025 and allowed the petition, holding that where goods were accompanied by an e-way bill and tax invoice identifying a registered dealer, any liability could only arise under Section 129(1)(a) of the U.P. Goods and Services Tax Act, 2017; the Adjudicating Authority erred in computing penalty under Section 129(1)(b). The matter is remitted to the tax authorities to quantify the penalty in accordance with Section 129(1)(a) within three weeks of the order. The petition is disposed of; parties are directed to comply with the remittal for calculation of the appropriate penalty.
The HC set aside the impugned order dated 18.10.2025 and allowed the petition, holding that where goods were accompanied by an e-way bill and tax invoice identifying a registered dealer, any liability could only arise under Section 129(1)(a) of the U.P. Goods and Services Tax Act, 2017; the Adjudicating Authority erred in computing penalty under Section 129(1)(b). The matter is remitted to the tax authorities to quantify the penalty in accordance with Section 129(1)(a) within three weeks of the order. The petition is disposed of; parties are directed to comply with the remittal for calculation of the appropriate penalty.
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