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 Show Cause Notice (SCN) demanding Integrated Goods and Services Tax (IGST) on the activity of holding equity capital by the Holding Companies in the Petitioner company and on the External Commercial Borrowing (ECB) received by the Petitioner from AOSH was not properly considered. The court quashed the SCN insofar as it relates to the proposal to levy/demand GST on 'Continuous Equity Share holding' and remitted the matter back to the respondent for reconsideration after providing an opportunity to the petitioner regarding the issue of 'Value of the Credit Grant in Service determined as a service fee @1%'. The petitioner was granted liberty to submit its response on this issue within four weeks.
The High Court held that the Show Cause Notice (SCN) demanding Integrated Goods and Services Tax (IGST) on the activity of holding equity capital by the Holding Companies in the Petitioner company and on the External Commercial Borrowing (ECB) received by the Petitioner from AOSH was not properly considered. The court quashed the SCN insofar as it relates to the proposal to levy/demand GST on 'Continuous Equity Share holding' and remitted the matter back to the respondent for reconsideration after providing an opportunity to the petitioner regarding the issue of 'Value of the Credit Grant in Service determined as a service fee @1%'. The petitioner was granted liberty to submit its response on this issue within four weeks.
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