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 court held that the denial of input tax credit to the petitioner by the respondent authority requires reconsideration. The respondent failed to consider the petitioner's contention that the payments for which input tax credit was sought were made against the provisional registration number before the permanent registration number was granted. There were no reasons provided for disallowing such credit to the petitioner. Consequently, the matter was remanded for fresh consideration by the respondent authority.
The court held that the denial of input tax credit to the petitioner by the respondent authority requires reconsideration. The respondent failed to consider the petitioner's contention that the payments for which input tax credit was sought were made against the provisional registration number before the permanent registration number was granted. There were no reasons provided for disallowing such credit to the petitioner. Consequently, the matter was remanded for fresh consideration by the respondent authority.
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