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...
Supply classified as works contract u/s 2(119) of CGST Act. Applicant executes deposit works on behalf of consumers/agencies under two modes. In second mode, applicant eligible for input tax credit on materials, labor, installation, and overheads as per Section 16, not blocked u/s 17(5). Ownership vests with applicant after construction, but work done on behalf of customers, not on applicant's own account. Hence, input tax credit available despite applicant being custodian of constructed lines credited in books.
Supply classified as works contract u/s 2(119) of CGST Act. Applicant executes deposit works on behalf of consumers/agencies under two modes. In second mode, applicant eligible for input tax credit on materials, labor, installation, and overheads as per Section 16, not blocked u/s 17(5). Ownership vests with applicant after construction, but work done on behalf of customers, not on applicant's own account. Hence, input tax credit available despite applicant being custodian of constructed lines credited in books.
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