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...
ITC of GST paid on services for surrendering leasehold rights not eligible when construction activity not undertaken on leasehold land. SC in Safari Retreats laid down functionality test - if building qualifies as plant, ITC available for renting/leasing, else not available if for recipient's own use. Appellant did not construct on leasehold land acquired from GACL despite stating 99.85% utilization for plant/machinery. GST paid on surrendering leasehold rights ineligible for ITC. Appeal dismissed by AAAR.
ITC of GST paid on services for surrendering leasehold rights not eligible when construction activity not undertaken on leasehold land. SC in Safari Retreats laid down functionality test - if building qualifies as plant, ITC available for renting/leasing, else not available if for recipient's own use. Appellant did not construct on leasehold land acquired from GACL despite stating 99.85% utilization for plant/machinery. GST paid on surrendering leasehold rights ineligible for ITC. Appeal dismissed by AAAR.
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