Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Refund was denied where goods were moved under an e-way bill containing an incorrect destination address, and the plea of inadvertent error was rejected. The court held that the taxpayer had adequate opportunity to seek correction, and unlike relied-on precedents, the consignor and consignee being the same negated the claim of a bona fide mistake. The court further found that repeated similar "address errors" could indicate a modus operandi, and the taxpayer produced no corroborative records (such as ledgers, books, or movement registers) to prove that the goods were actually meant for the stated warehouse. The writ petition was dismissed. - HC
Refund was denied where goods were moved under an e-way bill containing an incorrect destination address, and the plea of inadvertent error was rejected. The court held that the taxpayer had adequate opportunity to seek correction, and unlike relied-on precedents, the consignor and consignee being the same negated the claim of a bona fide mistake. The court further found that repeated similar "address errors" could indicate a modus operandi, and the taxpayer produced no corroborative records (such as ledgers, books, or movement registers) to prove that the goods were actually meant for the stated warehouse. The writ petition was dismissed. - HC
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