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 High Court held that the negative blocking of the Electronic Credit Ledger (ECL) of the writ petitioner by the respondents, purportedly exercising powers u/r 86A of the Central Goods and Services Tax Rules, 2017, cannot be sustained. The issue of negative blocking stands conclusively decided in favor of the writ petitioner in light of the judgment in Best Crop Science Pvt. Ltd. v. Principal Commissioner, where it was held that orders disallowing debit from the ECL in excess of the available Input Tax Credit at the time of passing such orders (referred to as Negative blocking) are set aside. Consequently, the petition was allowed.
The High Court held that the negative blocking of the Electronic Credit Ledger (ECL) of the writ petitioner by the respondents, purportedly exercising powers u/r 86A of the Central Goods and Services Tax Rules, 2017, cannot be sustained. The issue of negative blocking stands conclusively decided in favor of the writ petitioner in light of the judgment in Best Crop Science Pvt. Ltd. v. Principal Commissioner, where it was held that orders disallowing debit from the ECL in excess of the available Input Tax Credit at the time of passing such orders (referred to as Negative blocking) are set aside. Consequently, the petition was allowed.
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