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 held that validly availed input tax credit (ITC) is indefeasible unless utilized improperly. The imposition of interest u/s 50(3) requires actual utilization of the credit. Since the petitioner had not utilized the accumulated ITC after the cut-off date, the imposition of interest as per the impugned circular could not be justified. The petition was allowed.
The HC held that validly availed input tax credit (ITC) is indefeasible unless utilized improperly. The imposition of interest u/s 50(3) requires actual utilization of the credit. Since the petitioner had not utilized the accumulated ITC after the cut-off date, the imposition of interest as per the impugned circular could not be justified. The petition was allowed.
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