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 Cess under Clean Energy Cess’ 2010 - The court held that the revenue could levy Clean Energy Cess on coal produced and lying in stock as of 30th June 2017, as per Section 83(3) of the Finance Act, 2010. This levy was valid despite the repeal of Clean Energy Cess by the GST Compensation Cess under the Goods & Services (Compensation to States) Act, 2017, since the taxable event (production of coal) occurred when the cess was in force. - However, demand confirmed for normal period of limitation only - HC
Levy of Cess under Clean Energy Cess’ 2010 - The court held that the revenue could levy Clean Energy Cess on coal produced and lying in stock as of 30th June 2017, as per Section 83(3) of the Finance Act, 2010. This levy was valid despite the repeal of Clean Energy Cess by the GST Compensation Cess under the Goods & Services (Compensation to States) Act, 2017, since the taxable event (production of coal) occurred when the cess was in force. - However, demand confirmed for normal period of limitation only - HC
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