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...
Petitioner challenged denial of input tax credit (ITC) on manpower supply services received during 2017-18 to 2022-23, citing Circular No. 211/5/2024-GST. Court held petitioner entitled to ITC and cannot be deprived or liable for interest due to belated claim, as per circular. Circular supports petitioner's claim, binding on respondents as per KP Varghese judgment. However, as circular issued during pendency, respondent didn't have its benefit earlier. Petition disposed, directing respondent to consider petitioner's objections within three weeks, bearing in mind circular and pass orders accordingly. Petitioner granted liberty to file objections to show cause notice.
Petitioner challenged denial of input tax credit (ITC) on manpower supply services received during 2017-18 to 2022-23, citing Circular No. 211/5/2024-GST. Court held petitioner entitled to ITC and cannot be deprived or liable for interest due to belated claim, as per circular. Circular supports petitioner's claim, binding on respondents as per KP Varghese judgment. However, as circular issued during pendency, respondent didn't have its benefit earlier. Petition disposed, directing respondent to consider petitioner's objections within three weeks, bearing in mind circular and pass orders accordingly. Petitioner granted liberty to file objections to show cause notice.
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