Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Where the taxpayer had voluntarily intimated short payment and its willingness to discharge tax much before any enforcement action, the essential preconditions of fraud, wilful misstatement, or suppression were not made out, rendering invocation of s.74 GST impermissible; consequently, denial of ITC by applying s.39(9) could not be sustained, and the proceedings were quashed. The taxpayer's earlier payment at a higher rate treating the supply as composite "to buy peace" was held not to operate as waiver or estoppel; it could still raise the composite-versus-individual supply issue before the competent authority, which must decide it on merits without relying on the prior admission. - HC
Where the taxpayer had voluntarily intimated short payment and its willingness to discharge tax much before any enforcement action, the essential preconditions of fraud, wilful misstatement, or suppression were not made out, rendering invocation of s.74 GST impermissible; consequently, denial of ITC by applying s.39(9) could not be sustained, and the proceedings were quashed. The taxpayer's earlier payment at a higher rate treating the supply as composite "to buy peace" was held not to operate as waiver or estoppel; it could still raise the composite-versus-individual supply issue before the competent authority, which must decide it on merits without relying on the prior admission. - HC
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