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...
Transfer of title of goods stored in Free Trade Warehousing Zone (FTWZ) by the appellant to customers in Domestic Tariff Area (DTA) or multiple transfers within FTWZ is covered under paragraph 8(a) of Schedule III of CGST Act, 2017 as "Supply of warehoused goods to any person before clearance for home consumption". It does not fall under paragraph 8(b) regarding endorsement of documents of title to goods. IGST is applicable on such supplies from FTWZ to DTA customers. No reversal of input tax credit is required under amended Section 17(3) of CGST Act for these supplies, except for supplies from duty-free shops at international airports.
Transfer of title of goods stored in Free Trade Warehousing Zone (FTWZ) by the appellant to customers in Domestic Tariff Area (DTA) or multiple transfers within FTWZ is covered under paragraph 8(a) of Schedule III of CGST Act, 2017 as "Supply of warehoused goods to any person before clearance for home consumption". It does not fall under paragraph 8(b) regarding endorsement of documents of title to goods. IGST is applicable on such supplies from FTWZ to DTA customers. No reversal of input tax credit is required under amended Section 17(3) of CGST Act for these supplies, except for supplies from duty-free shops at international airports.
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