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...
Profiteering - supply of “Services by way of admission to exhibition of cinematography films”. - The Commission concluded that there was no 'Exception Category' of tickets, and the term was coined by the DGAP. The Respondent had sold 'Exception Category' cinema tickets only after 23.08.2019, charging GST @ 18%, and no benefit of tax reduction was required to be passed on to these tickets. - The Commission further noted that the Respondent increased the base prices of 'Exception' category tickets after about 6 months from 23.08.2019, after passing on the benefit of tax reduction. This increase in base prices did not attract the Anti-Profiteering Provisions.
Profiteering - supply of “Services by way of admission to exhibition of cinematography films”. - The Commission concluded that there was no 'Exception Category' of tickets, and the term was coined by the DGAP. The Respondent had sold 'Exception Category' cinema tickets only after 23.08.2019, charging GST @ 18%, and no benefit of tax reduction was required to be passed on to these tickets. - The Commission further noted that the Respondent increased the base prices of 'Exception' category tickets after about 6 months from 23.08.2019, after passing on the benefit of tax reduction. This increase in base prices did not attract the Anti-Profiteering Provisions.
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