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...
The High Court addressed the issue of determining the value of supply in a job work scenario, challenging an order u/s 107 of the WBGST/CGST Act, 2017. The petitioner received goods for job work from outside the state, but faced interception and detention while returning the consignment after completion. The Court noted that if the value of supply cannot be determined u/s 15(1), it should be as prescribed. The petitioner did not disclose the contract, affecting value determination. The proper officer did not assess the transaction value under Section 15(1). The Court remanded the matter to the appellate authority for reevaluation, directing the petitioner to disclose all job work documents within 3 weeks. Petition disposed off.
The High Court addressed the issue of determining the value of supply in a job work scenario, challenging an order u/s 107 of the WBGST/CGST Act, 2017. The petitioner received goods for job work from outside the state, but faced interception and detention while returning the consignment after completion. The Court noted that if the value of supply cannot be determined u/s 15(1), it should be as prescribed. The petitioner did not disclose the contract, affecting value determination. The proper officer did not assess the transaction value under Section 15(1). The Court remanded the matter to the appellate authority for reevaluation, directing the petitioner to disclose all job work documents within 3 weeks. Petition disposed off.
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