Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
The High Court rectified its previous order, holding that Notification No. 54/2018 Central Tax shall apply prospectively from 9th October 2018 only. Consequently, the show cause notice dated 31.03.2023, issued on the basis of retrospective operation of the said Notification for the period prior to 9.10.2018, was quashed as being without jurisdiction. The amount quantified towards alleged erroneous refund for the period before 9.10.2018 would not survive, as the Notification would be applicable prospectively. The petition was disposed of accordingly.
The High Court rectified its previous order, holding that Notification No. 54/2018 Central Tax shall apply prospectively from 9th October 2018 only. Consequently, the show cause notice dated 31.03.2023, issued on the basis of retrospective operation of the said Notification for the period prior to 9.10.2018, was quashed as being without jurisdiction. The amount quantified towards alleged erroneous refund for the period before 9.10.2018 would not survive, as the Notification would be applicable prospectively. The petition was disposed of accordingly.
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