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...
Classification dispute regarding Geo Membrane manufactured by petitioner - whether to be classified under Chapter 59 or Chapter 39 of Tariff. Court relied on Coordinate Bench decision in MESSERS CTM TECHNICAL TEXTILES LTD case, holding product falls under Chapter 59, not Chapter 39 as ruled by Gujarat Advance Ruling Authority. Petitioner liable to pay GST at 12% from 15.11.2017 under HSN Code 59111000, not 18%. Respondent authority directed to apply discounted 12% GST rate on petitioner's product. Petition allowed.
Classification dispute regarding Geo Membrane manufactured by petitioner - whether to be classified under Chapter 59 or Chapter 39 of Tariff. Court relied on Coordinate Bench decision in MESSERS CTM TECHNICAL TEXTILES LTD case, holding product falls under Chapter 59, not Chapter 39 as ruled by Gujarat Advance Ruling Authority. Petitioner liable to pay GST at 12% from 15.11.2017 under HSN Code 59111000, not 18%. Respondent authority directed to apply discounted 12% GST rate on petitioner's product. Petition allowed.
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