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...
Entitlement for issuance of C-Forms post the introduction of G.S.T. regime for natural gas - The High court extensively reviewed the applicability of C-Forms in the post-GST regime and reaffirmed that despite the GST implementation, certain transactions still fell under the purview of the CST Act due to the continued definition of some goods like natural gas. It was determined that the petitioner was entitled to the concessional rate of 2% if it provided the necessary C-Forms. The court also noted the confusion and transitional issues between the VAT and GST systems, which affected the submission of these forms. The court ultimately ruled in favor of the petitioner, directing the tax authorities to process the refund based on the C-Forms submitted.
Entitlement for issuance of C-Forms post the introduction of G.S.T. regime for natural gas - The High court extensively reviewed the applicability of C-Forms in the post-GST regime and reaffirmed that despite the GST implementation, certain transactions still fell under the purview of the CST Act due to the continued definition of some goods like natural gas. It was determined that the petitioner was entitled to the concessional rate of 2% if it provided the necessary C-Forms. The court also noted the confusion and transitional issues between the VAT and GST systems, which affected the submission of these forms. The court ultimately ruled in favor of the petitioner, directing the tax authorities to process the refund based on the C-Forms submitted.
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