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...
Refund of unutilized CENVAT Credit - The period involved is April, 2017 to June, 2017 and the refund claim was made in June, 2018, which is perhaps within the period of one year but, however, by that time it is an undisputed fact that the GST regime had taken over by which filing of ST-3 Return was done-away. There is also no denial by the Revenue as to the claim of the appellant that subsequent to the filing of TRAN-1 Return, the refund amount was debited in its GSTR-3B/Electronic Credit Ledger - The denial of refund is not in accordance with law - AT
Refund of unutilized CENVAT Credit - The period involved is April, 2017 to June, 2017 and the refund claim was made in June, 2018, which is perhaps within the period of one year but, however, by that time it is an undisputed fact that the GST regime had taken over by which filing of ST-3 Return was done-away. There is also no denial by the Revenue as to the claim of the appellant that subsequent to the filing of TRAN-1 Return, the refund amount was debited in its GSTR-3B/Electronic Credit Ledger - The denial of refund is not in accordance with law - AT
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