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 - determination of the turn over for the purpose of refund - After considering the submissions, the High Court found merit in the petitioner's argument that the issue could be re-examined in light of Circular No. 197/09/2023-GST. The court noted the clarification provided in paragraph 3 of the circular regarding the calculation of adjusted total turnover for the purpose of refund. Therefore, the High Court set aside the impugned order and remitted the case back to the respondent to pass orders afresh on merits and in accordance with law.
Refund claim - determination of the turn over for the purpose of refund - After considering the submissions, the High Court found merit in the petitioner's argument that the issue could be re-examined in light of Circular No. 197/09/2023-GST. The court noted the clarification provided in paragraph 3 of the circular regarding the calculation of adjusted total turnover for the purpose of refund. Therefore, the High Court set aside the impugned order and remitted the case back to the respondent to pass orders afresh on merits and in accordance with law.
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