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...
Remand order issued in case concerning refund of accumulated input tax credit (ITC) for zero-rated supply due to mismatch in ITC as per GSTR-2B and GSTR-3B. Adjudicating authority faulted for not examining reconciliation statement and passing refund order without sufficient discussion. Appellate authority also failed to address reconciliation issue as required u/s 107(11) of CGST Act. Matter remanded to appellate authority for fresh consideration by setting aside impugned order.
Remand order issued in case concerning refund of accumulated input tax credit (ITC) for zero-rated supply due to mismatch in ITC as per GSTR-2B and GSTR-3B. Adjudicating authority faulted for not examining reconciliation statement and passing refund order without sufficient discussion. Appellate authority also failed to address reconciliation issue as required u/s 107(11) of CGST Act. Matter remanded to appellate authority for fresh consideration by setting aside impugned order.
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