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...
Refund claim - export of service - zero rated supply - receipt in convertible foreign exchange - Amount received through Paypal in Indian currency - The High Court observed that payments received through PayPal, acting as an intermediary, and credited in Indian Rupees after conversion, complied with the FEMA regulations and RBI guidelines. - The court determined that the failure to directly receive payments in foreign currency or produce export invoices does not automatically disqualify the petitioner from refund eligibility, as the essence of the transactions met the criteria for "export of service". - Consequently, the petitioner is entitled for export of tax paid on export and the unutilized input tax credit used in export of service. - Refund allowed.
Refund claim - export of service - zero rated supply - receipt in convertible foreign exchange - Amount received through Paypal in Indian currency - The High Court observed that payments received through PayPal, acting as an intermediary, and credited in Indian Rupees after conversion, complied with the FEMA regulations and RBI guidelines. - The court determined that the failure to directly receive payments in foreign currency or produce export invoices does not automatically disqualify the petitioner from refund eligibility, as the essence of the transactions met the criteria for "export of service". - Consequently, the petitioner is entitled for export of tax paid on export and the unutilized input tax credit used in export of service. - Refund allowed.
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