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...
Input tax credit on statutory canteen services is restricted by the blocked credit rule for food and beverages, but credit remains available where the employer is legally obliged to provide the facility under the Factories Act. Accordingly, canteen services for regular employees qualified only to the extent the cost was actually borne by the employer; any portion recovered from employees was outside admissible credit. Canteen services attributable to contract workers did not qualify, because they were not employees, no corresponding statutory obligation was shown, and the inward service was not used for any outward supply of the same category. The admissibility of credit was therefore confined to the employer's own statutory expenditure.
Input tax credit on statutory canteen services is restricted by the blocked credit rule for food and beverages, but credit remains available where the employer is legally obliged to provide the facility under the Factories Act. Accordingly, canteen services for regular employees qualified only to the extent the cost was actually borne by the employer; any portion recovered from employees was outside admissible credit. Canteen services attributable to contract workers did not qualify, because they were not employees, no corresponding statutory obligation was shown, and the inward service was not used for any outward supply of the same category. The admissibility of credit was therefore confined to the employer's own statutory expenditure.
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