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...
Interest liability on delayed payment GST - The court held that the credit to the Government's account occurs not later than the last date for filing monthly returns as per Section 39(7) of the GST Act. Once payment is made through GST PMT-06, it is initially credited to the Government's account, discharging the tax liability to the extent of the deposit made. For accounting purposes, it is then deemed to be credited to the Electronic Cash Ledger (ECL). The court clarified that as long as the GST collected is credited to the Government's account by the filing deadline, the tax liability is considered discharged from the date of credit to the Government's account. If there is a default in payment post the due date, interest is payable under Section 50(1) of the Act for the delayed period. - HC
Interest liability on delayed payment GST - The court held that the credit to the Government's account occurs not later than the last date for filing monthly returns as per Section 39(7) of the GST Act. Once payment is made through GST PMT-06, it is initially credited to the Government's account, discharging the tax liability to the extent of the deposit made. For accounting purposes, it is then deemed to be credited to the Electronic Cash Ledger (ECL). The court clarified that as long as the GST collected is credited to the Government's account by the filing deadline, the tax liability is considered discharged from the date of credit to the Government's account. If there is a default in payment post the due date, interest is payable under Section 50(1) of the Act for the delayed period. - HC
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