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...
The High Court held that the petitioner is entitled to refund of unutilized Input Tax Credit (ITC) on export of goods u/s 16(3) of the Integrated Goods and Services Tax Act, 2017. The petitioner furnished Bank Realization Certificates (BRCs) evidencing realization of sale proceeds, and the application for refund could not be rejected solely on the ground of non-production of BRCs within nine months. Regarding furnishing bank statements and ledger accounts of suppliers, the matter was remanded to the adjudicating authority to decide afresh whether the petitioner made payment to suppliers for inward supplies against which refund of accumulated ITC is claimed.
The High Court held that the petitioner is entitled to refund of unutilized Input Tax Credit (ITC) on export of goods u/s 16(3) of the Integrated Goods and Services Tax Act, 2017. The petitioner furnished Bank Realization Certificates (BRCs) evidencing realization of sale proceeds, and the application for refund could not be rejected solely on the ground of non-production of BRCs within nine months. Regarding furnishing bank statements and ledger accounts of suppliers, the matter was remanded to the adjudicating authority to decide afresh whether the petitioner made payment to suppliers for inward supplies against which refund of accumulated ITC is claimed.
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