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...
Seeking reimbursement of GST amount paid by the petitioner - Interpretation of Contract Clause - After analyzing the documents and submissions, the High Court found that the petitioner's quoted rates were indeed exclusive of GST and that the respondent had already reimbursed GST for previous bills. The court rejected the respondent's interpretation of the contract clause, stating that there was no evidence to support that it included GST. Therefore, the court directed the respondent to reimburse the GST paid by the petitioner on all bills within a specified timeframe.
Seeking reimbursement of GST amount paid by the petitioner - Interpretation of Contract Clause - After analyzing the documents and submissions, the High Court found that the petitioner's quoted rates were indeed exclusive of GST and that the respondent had already reimbursed GST for previous bills. The court rejected the respondent's interpretation of the contract clause, stating that there was no evidence to support that it included GST. Therefore, the court directed the respondent to reimburse the GST paid by the petitioner on all bills within a specified timeframe.
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