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...
Where Rule 80(3) applies, Form GSTR-9C forms part of the annual return required under Section 44, so filing Form GSTR-9 without the reconciliation statement amounts to failure to furnish the return by the due date. On that basis, late fee under Section 47(2) is attracted for delayed filing of Form GSTR-9C, and the challenge to the levy failed. The HC did not follow Anishia Chandrakanth and upheld the assessment, while leaving the petitioner liberty to pursue an appeal on factual aspects.
Where Rule 80(3) applies, Form GSTR-9C forms part of the annual return required under Section 44, so filing Form GSTR-9 without the reconciliation statement amounts to failure to furnish the return by the due date. On that basis, late fee under Section 47(2) is attracted for delayed filing of Form GSTR-9C, and the challenge to the levy failed. The HC did not follow Anishia Chandrakanth and upheld the assessment, while leaving the petitioner liberty to pursue an appeal on factual aspects.
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