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...
Advance ruling proceedings under GST are limited to interpretation of the tax law and cannot conclusively determine whether a product is biodegradable or compostable as a scientific or environmental fact. The AAAR noted that the concessional rate for non-paper bags applies only where the bags are in fact biodegradable, but the certificates under the Plastic Waste Management Rules only permitted manufacture and sale subject to compliance, and the test reports relied on were not fully neutral. It therefore held that the legal position is that the concession applies if the goods are biodegradable, while the actual determination must be made by competent environmental authorities or through testing by the jurisdictional GST field formation.
Advance ruling proceedings under GST are limited to interpretation of the tax law and cannot conclusively determine whether a product is biodegradable or compostable as a scientific or environmental fact. The AAAR noted that the concessional rate for non-paper bags applies only where the bags are in fact biodegradable, but the certificates under the Plastic Waste Management Rules only permitted manufacture and sale subject to compliance, and the test reports relied on were not fully neutral. It therefore held that the legal position is that the concession applies if the goods are biodegradable, while the actual determination must be made by competent environmental authorities or through testing by the jurisdictional GST field formation.
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