Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Valuation u/s 15(3) - Validity of GST on volume discount - Petitioner submited that, GST is levied and paid on the entire invoice amount, which includes volume discount. - Demand of GST on volume discount would be double taxation. - The High Court observed that, there is no scope for confusing the discount offered to the petitioner and the discounted price at which the petitioner effects further sale to its customers. They are two independent transactions and there is no scope for intermingling them for demanding tax from the petitioner. The discounted price at which the petitioner sells the goods is relevant only for determining the “transaction value” adopted by the petitioner. - Consequently, HC restored back the matter to AO for fresh adjudication.
Valuation u/s 15(3) - Validity of GST on volume discount - Petitioner submited that, GST is levied and paid on the entire invoice amount, which includes volume discount. - Demand of GST on volume discount would be double taxation. - The High Court observed that, there is no scope for confusing the discount offered to the petitioner and the discounted price at which the petitioner effects further sale to its customers. They are two independent transactions and there is no scope for intermingling them for demanding tax from the petitioner. The discounted price at which the petitioner sells the goods is relevant only for determining the “transaction value” adopted by the petitioner. - Consequently, HC restored back the matter to AO for fresh adjudication.
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