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...
Rectification application dismissed as error not apparent on record. Excess GST collected from customers to be refunded to them before claiming refund from tax authorities to avoid unjust enrichment. Classifying "other charges" as consideration for construction services under HSN Code 9954 or separate services under respective heads not a rectifiable mistake. AAR ruling upheld in interest of equity and uniformity among flat buyers, irrespective of projects or timelines.
Rectification application dismissed as error not apparent on record. Excess GST collected from customers to be refunded to them before claiming refund from tax authorities to avoid unjust enrichment. Classifying "other charges" as consideration for construction services under HSN Code 9954 or separate services under respective heads not a rectifiable mistake. AAR ruling upheld in interest of equity and uniformity among flat buyers, irrespective of projects or timelines.
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