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...
Advance ruling application regarding maintainability, levy of GST on network/wheeling charges, cross-subsidy surcharge, additional surcharge, and fees and charges related to electricity distribution services was not admitted u/s 98(2) of CGST/TNGST Act, 2017 insofar as it relates to taxability of services. Applicant's argument regarding interpretation of "applicant" was rejected. Clarification provided on internal mechanism of "call book" and its non-applicability in this case. Application disposed of by not admitting it for services in question as per Section 98(2) of CGST Act, 2017.
Advance ruling application regarding maintainability, levy of GST on network/wheeling charges, cross-subsidy surcharge, additional surcharge, and fees and charges related to electricity distribution services was not admitted u/s 98(2) of CGST/TNGST Act, 2017 insofar as it relates to taxability of services. Applicant's argument regarding interpretation of "applicant" was rejected. Clarification provided on internal mechanism of "call book" and its non-applicability in this case. Application disposed of by not admitting it for services in question as per Section 98(2) of CGST Act, 2017.
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