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...
Ineligibility for claiming ITC on inward supplies of goods or services used for construction on account of own use - The appellant contested the restriction on ITC for immovable property construction, arguing it should apply only to capitalized expenses. The respondent countered that the restriction applies regardless of capitalization. The Appellate Authority (AAAR) affirmed that the restriction applies to all construction expenses, regardless of capitalization, concluding that ITC for such construction is not available.
Ineligibility for claiming ITC on inward supplies of goods or services used for construction on account of own use - The appellant contested the restriction on ITC for immovable property construction, arguing it should apply only to capitalized expenses. The respondent countered that the restriction applies regardless of capitalization. The Appellate Authority (AAAR) affirmed that the restriction applies to all construction expenses, regardless of capitalization, concluding that ITC for such construction is not available.
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