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...
GST on works contract - estimation of value - contract period was extended beyond 01.07.2017 - the task of determining the differential GST, i.e. segregating labour, material, etc. is of the Authority vested with power under the CGST/OGST Act and not within the domain of any other. Such segregation can be made keeping in view inter alia Revised Guidelines dated 10th December 2018 issued by the Finance Department, Government of Odisha - The question whether, in fact, any amount is owed to the Petitioner by Opposite Parties on account of GST deducted from its bills or vice versa, has become a highly disputed question of fact. The claim of the Petitioner ultimately, in simple terms, is one for money which it seeks as reimbursement from Opposite Parties. It is not possible for this Court in its writ jurisdiction under Article 226 of the Constitution to calculate on a case to case basis - writ petition dismissed - HC
GST on works contract - estimation of value - contract period was extended beyond 01.07.2017 - the task of determining the differential GST, i.e. segregating labour, material, etc. is of the Authority vested with power under the CGST/OGST Act and not within the domain of any other. Such segregation can be made keeping in view inter alia Revised Guidelines dated 10th December 2018 issued by the Finance Department, Government of Odisha - The question whether, in fact, any amount is owed to the Petitioner by Opposite Parties on account of GST deducted from its bills or vice versa, has become a highly disputed question of fact. The claim of the Petitioner ultimately, in simple terms, is one for money which it seeks as reimbursement from Opposite Parties. It is not possible for this Court in its writ jurisdiction under Article 226 of the Constitution to calculate on a case to case basis - writ petition dismissed - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
