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...
Breakwater construction not considered 'plant and machinery' for input tax credit eligibility under GST. Petitioner's services involve regassification of LNG, and breakwater ensures safety of berthed ships, not used for outward supply. Dictionary meaning of 'plant' indicates industrial activity/production place, which breakwater does not qualify as. Explanation to Section 17 requires plant and machinery to be used for outward supply, not satisfied here. High Court finds no infirmity in order, dismisses petition.
Breakwater construction not considered 'plant and machinery' for input tax credit eligibility under GST. Petitioner's services involve regassification of LNG, and breakwater ensures safety of berthed ships, not used for outward supply. Dictionary meaning of 'plant' indicates industrial activity/production place, which breakwater does not qualify as. Explanation to Section 17 requires plant and machinery to be used for outward supply, not satisfied here. High Court finds no infirmity in order, dismisses petition.
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