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...
Interest on delayed GST payments is refundable where the tax was credited to the Electronic Cash Ledger before the return-filing due date, despite belated filing of the GST return. The note explains that a refund rejection based solely on the prospective operation of the proviso to Rule 88B was inconsistent with the applicable High Court precedent on interest computation. It states that the refund rejection and recovery notice were quashed, and the taxpayer was directed to receive the excess interest refund with statutory interest.
Interest on delayed GST payments is refundable where the tax was credited to the Electronic Cash Ledger before the return-filing due date, despite belated filing of the GST return. The note explains that a refund rejection based solely on the prospective operation of the proviso to Rule 88B was inconsistent with the applicable High Court precedent on interest computation. It states that the refund rejection and recovery notice were quashed, and the taxpayer was directed to receive the excess interest refund with statutory interest.
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