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...
A separate reverse charge levy on the service component of CIF imports under Notifications Nos. 8/2017 and 10/2017 was held unsustainable because the same element was already included within the composite supply of imported goods. Relying on the Supreme Court's ruling in Mohit Minerals, the HC applied the principle that the service aspect cannot be taxed separately in a manner that conflicts with the statutory scheme of composite supply. As the show cause notice was founded on that invalid levy, it could not be sustained and was set aside, bringing the proceedings to an end.
A separate reverse charge levy on the service component of CIF imports under Notifications Nos. 8/2017 and 10/2017 was held unsustainable because the same element was already included within the composite supply of imported goods. Relying on the Supreme Court's ruling in Mohit Minerals, the HC applied the principle that the service aspect cannot be taxed separately in a manner that conflicts with the statutory scheme of composite supply. As the show cause notice was founded on that invalid levy, it could not be sustained and was set aside, bringing the proceedings to an end.
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