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...
Blocking of Input Tax Credit (ITC) - contravention of Rule 86A - The High court observed that while Rule 86A does not stipulate a prior notice, it requires the contemporaneous communication of reasons in writing to the assessee. In this case, apart from mentioning the name of the supplier in the electronic credit ledger, no reasons were provided to the petitioner. Therefore, the petitioner is entitled to the unblocking of ITC.
Blocking of Input Tax Credit (ITC) - contravention of Rule 86A - The High court observed that while Rule 86A does not stipulate a prior notice, it requires the contemporaneous communication of reasons in writing to the assessee. In this case, apart from mentioning the name of the supplier in the electronic credit ledger, no reasons were provided to the petitioner. Therefore, the petitioner is entitled to the unblocking of ITC.
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