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 HC granted time to the respondents to file a reply challenging the circular dated 27.10.2023 and the petitioner's contention that providing a corporate guarantee by a holding company to its subsidiary does not constitute a "supply" or "supply of service" taxable u/s 9 of the CGST Act, 2017. The HC stayed the operation of the impugned circular dated 27.10.2023 regarding Item No. 2 until further orders.
The HC granted time to the respondents to file a reply challenging the circular dated 27.10.2023 and the petitioner's contention that providing a corporate guarantee by a holding company to its subsidiary does not constitute a "supply" or "supply of service" taxable u/s 9 of the CGST Act, 2017. The HC stayed the operation of the impugned circular dated 27.10.2023 regarding Item No. 2 until further orders.
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