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...
Section 171(1) requires GST rate-reduction benefits on cinema admission tickets to be passed to recipients through a commensurate reduction in cum-tax ticket prices. Retaining the same ticket price by increasing the pre-tax base price does not satisfy this obligation. Directions permitting collection of proposed cinema fares and representations to licensing authorities do not create an exception to the anti-profiteering requirement, particularly where approval is unsubstantiated or relates to later periods. Profiteering may be quantified by retaining the pre-reduction base price, applying the reduced GST rate to determine the commensurate price, and calculating excess collections from actual ticket sales, while excluding correctly accounted transactions at other rates.
Section 171(1) requires GST rate-reduction benefits on cinema admission tickets to be passed to recipients through a commensurate reduction in cum-tax ticket prices. Retaining the same ticket price by increasing the pre-tax base price does not satisfy this obligation. Directions permitting collection of proposed cinema fares and representations to licensing authorities do not create an exception to the anti-profiteering requirement, particularly where approval is unsubstantiated or relates to later periods. Profiteering may be quantified by retaining the pre-reduction base price, applying the reduced GST rate to determine the commensurate price, and calculating excess collections from actual ticket sales, while excluding correctly accounted transactions at other rates.
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