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 of Cenvat credit availed on Education Cess and Higher Secondary Education Cess carried forward as on the appointed day i.e. 30.06.2017 in terms of Section 142(3) of the CGST Act 2017 - The Tribunal upheld the department's decision to reject the refund claim, citing Section 142(3) of the CGST Act, 2017. It noted that the entire refund claim amount had been carried forward by the appellant, making them ineligible for the refund.
Refund of Cenvat credit availed on Education Cess and Higher Secondary Education Cess carried forward as on the appointed day i.e. 30.06.2017 in terms of Section 142(3) of the CGST Act 2017 - The Tribunal upheld the department's decision to reject the refund claim, citing Section 142(3) of the CGST Act, 2017. It noted that the entire refund claim amount had been carried forward by the appellant, making them ineligible for the refund.
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