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...
Doctrine of mutuality - Levy of GST on services provided by association to members - Constitutional validity of relevant provisions of Central and State GST Acts questioned - Held, provisions are within legislative competence and do not violate fundamental rights or principles of taxation - However, retrospective operation from 01.07.2017 not permissible, provisions to have prospective effect from 01.01.2022 - Each activity of association to be examined independently to determine if it involves supply of goods/services for GST levy - Writ petitions dismissed with above observations.
Doctrine of mutuality - Levy of GST on services provided by association to members - Constitutional validity of relevant provisions of Central and State GST Acts questioned - Held, provisions are within legislative competence and do not violate fundamental rights or principles of taxation - However, retrospective operation from 01.07.2017 not permissible, provisions to have prospective effect from 01.01.2022 - Each activity of association to be examined independently to determine if it involves supply of goods/services for GST levy - Writ petitions dismissed with above observations.
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