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...
Retrospective amendment of the Foreign Trade Policy cannot deprive exporters or service providers of SEIS benefits accrued while an operative scheme covered their eligible services. The power to formulate or amend the policy does not authorise retrospective withdrawal of such accrued rights. Services rendered and foreign exchange earned during FY 2019-20 remained eligible despite later notifications introducing Appendix 3X and excluding specified services under Appendix 3E. The notifications operate prospectively from their respective issue dates, requiring processing of accrued SEIS claims and consequential benefits, including claims that could not previously be filed.
Retrospective amendment of the Foreign Trade Policy cannot deprive exporters or service providers of SEIS benefits accrued while an operative scheme covered their eligible services. The power to formulate or amend the policy does not authorise retrospective withdrawal of such accrued rights. Services rendered and foreign exchange earned during FY 2019-20 remained eligible despite later notifications introducing Appendix 3X and excluding specified services under Appendix 3E. The notifications operate prospectively from their respective issue dates, requiring processing of accrued SEIS claims and consequential benefits, including claims that could not previously be filed.
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