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...
Levy of CGST - scope of mutual contract / tender notification - the contention advanced by learned counsel for petitioner that, GST is not tax enabling the respondents to rely upon clause 44 of tender conditions, is devoid of merits. - petitioner is not at liberty to introduce any legal principle to his rescue so as to interfere with the rule of the game provided under Ext.P1 notice inviting tender, having an express stipulation for enhancement of rate of tax from time to time.
Levy of CGST - scope of mutual contract / tender notification - the contention advanced by learned counsel for petitioner that, GST is not tax enabling the respondents to rely upon clause 44 of tender conditions, is devoid of merits. - petitioner is not at liberty to introduce any legal principle to his rescue so as to interfere with the rule of the game provided under Ext.P1 notice inviting tender, having an express stipulation for enhancement of rate of tax from time to time.
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