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...
Storage of stock in premises not yet registered as an additional place of business did not, on the seizure records, justify confiscation of the available goods, redemption fine, or tax demand on the seized stock itself. The Court noted that the stock had not been liquidated at inspection and remained available, while the premises was later brought into the registration. The only consequence for the delayed registration default was a general penalty under the GST enactments. Tax, interest and penalty could still be redetermined only for any goods already sold.
Storage of stock in premises not yet registered as an additional place of business did not, on the seizure records, justify confiscation of the available goods, redemption fine, or tax demand on the seized stock itself. The Court noted that the stock had not been liquidated at inspection and remained available, while the premises was later brought into the registration. The only consequence for the delayed registration default was a general penalty under the GST enactments. Tax, interest and penalty could still be redetermined only for any goods already sold.
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