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...
GST levy on annuity received by petitioner - dispute on timing of liability. Authorities viewed liability arising from concession period commencement date, considering annuity for road maintenance. Petitioner disagreed. CBIC circular clarified tax payable on invoice issuance or annuity receipt, whichever earlier. HC set aside orders, directing authorities to collect tax per CBIC circular.
GST levy on annuity received by petitioner - dispute on timing of liability. Authorities viewed liability arising from concession period commencement date, considering annuity for road maintenance. Petitioner disagreed. CBIC circular clarified tax payable on invoice issuance or annuity receipt, whichever earlier. HC set aside orders, directing authorities to collect tax per CBIC circular.
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