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...
HC held that u/s 54 of CGST Act, 2017, failure to process IGST refund claim for goods exported is impermissible. Shipping Bill serves as refund application. Proper officer must issue order within 60 days of complete application. Circulars fix responsibility on officers and agents, not exporters. Refund must be allowed or rejected with reasons. Respondent directed to process and sanction Rs. 2,44,61,247 IGST refund within 4 weeks. Petition allowed.
HC held that u/s 54 of CGST Act, 2017, failure to process IGST refund claim for goods exported is impermissible. Shipping Bill serves as refund application. Proper officer must issue order within 60 days of complete application. Circulars fix responsibility on officers and agents, not exporters. Refund must be allowed or rejected with reasons. Respondent directed to process and sanction Rs. 2,44,61,247 IGST refund within 4 weeks. Petition allowed.
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