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...
Jurisdiction to issue SCN - Ocean Freight - contention of the petitioner is to the effect that, what has been sought to be invoked the Notification No. 8/2017-Integrated Tax (Rate) dated 28/6/2017 in issuing the show cause notice which itself has been struck down by the Division Bench of Gujarat High Court - The petitioner argued that the notice lacked jurisdiction due to the invalidity of the notification. The High Court upheld the petitioner's arguments, emphasizing the illegality of applying an ultra vires notification and the lack of jurisdiction in the show cause notice. It also reaffirmed the interpretation of GST laws established in previous judgments, supporting the petitioner's case. Overall, the court ruled in favor of the petitioner, setting aside the show cause notice and allowing for a refund of taxes paid under protest.
Jurisdiction to issue SCN - Ocean Freight - contention of the petitioner is to the effect that, what has been sought to be invoked the Notification No. 8/2017-Integrated Tax (Rate) dated 28/6/2017 in issuing the show cause notice which itself has been struck down by the Division Bench of Gujarat High Court - The petitioner argued that the notice lacked jurisdiction due to the invalidity of the notification. The High Court upheld the petitioner's arguments, emphasizing the illegality of applying an ultra vires notification and the lack of jurisdiction in the show cause notice. It also reaffirmed the interpretation of GST laws established in previous judgments, supporting the petitioner's case. Overall, the court ruled in favor of the petitioner, setting aside the show cause notice and allowing for a refund of taxes paid under protest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
