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...
Determination of whether an outward supply of goods procured by the applicant from an Indian company undergoing liquidation can be considered a zero-rated supply under GST, allowing export without payment of tax against a Letter of Undertaking (LUT). The key points are: The place of supply is within India as the goods are delivered to the applicant's premises in India. The applicant lacks GST registration in India, and the transaction does not qualify as an export of goods under GST law. Consequently, the transaction cannot be treated as a zero-rated supply under the GST Act, 2017, precluding the applicant from exporting the goods without paying tax against an LUT.
Determination of whether an outward supply of goods procured by the applicant from an Indian company undergoing liquidation can be considered a zero-rated supply under GST, allowing export without payment of tax against a Letter of Undertaking (LUT). The key points are: The place of supply is within India as the goods are delivered to the applicant's premises in India. The applicant lacks GST registration in India, and the transaction does not qualify as an export of goods under GST law. Consequently, the transaction cannot be treated as a zero-rated supply under the GST Act, 2017, precluding the applicant from exporting the goods without paying tax against an LUT.
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