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...
Input Tax Credit (ITC) claim - Non-payment to suppliers exceeding 180 days - Despite the petitioner's response and submission of supporting documents, including a Chartered Accountant's certificate, the assessing authority based its decision on the total trade payables of the petitioner without considering the specific payables related to Tamil Nadu. The court noted that companies are not required to file state-specific financial statements under the Companies Act, 2013. The petitioner agreed to provide invoices related to the sum attributable to Tamil Nadu. - Matter restored back for re-adjudication - HC
Input Tax Credit (ITC) claim - Non-payment to suppliers exceeding 180 days - Despite the petitioner's response and submission of supporting documents, including a Chartered Accountant's certificate, the assessing authority based its decision on the total trade payables of the petitioner without considering the specific payables related to Tamil Nadu. The court noted that companies are not required to file state-specific financial statements under the Companies Act, 2013. The petitioner agreed to provide invoices related to the sum attributable to Tamil Nadu. - Matter restored back for re-adjudication - HC
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