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 of certain errors apparent on face of order denied in AAR ruling. AR contended AAR should have ruled on all queries. Held: No error apparent on record noticed, so no rectification required. As Customs Act provisions not attracted, differential IGST paid by applicant ineligible for ITC u/s of CGST Act, 2017. No apparent error or mistake on record as alleged by applicant, so application for advance ruling liable for rejection u/s 98(2) of CGST/TNGST Acts, 2017.
Rectification of certain errors apparent on face of order denied in AAR ruling. AR contended AAR should have ruled on all queries. Held: No error apparent on record noticed, so no rectification required. As Customs Act provisions not attracted, differential IGST paid by applicant ineligible for ITC u/s of CGST Act, 2017. No apparent error or mistake on record as alleged by applicant, so application for advance ruling liable for rejection u/s 98(2) of CGST/TNGST Acts, 2017.
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