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 considered a case involving refund of accumulated credit due to inverted tax structure u/s 54(3) Proviso and Rule 89(5) of CGST Rules. The court held that the orders rejecting the refund claims were quashed and remanded for fresh consideration by the adjudicating authority. The petition was disposed of by way of remand for proper review of the refund claims in line with the law.
The High Court considered a case involving refund of accumulated credit due to inverted tax structure u/s 54(3) Proviso and Rule 89(5) of CGST Rules. The court held that the orders rejecting the refund claims were quashed and remanded for fresh consideration by the adjudicating authority. The petition was disposed of by way of remand for proper review of the refund claims in line with the law.
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