Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
HC determined that Notification No. 54/2018-Central Tax amending Rule 96(10) of CGST Rules operates prospectively from October 9, 2018, not retrospectively from October 23, 2017. The court quashed summons, notices, and recovery proceedings initiated based on retrospective application of the notification. Any quantification of alleged erroneous refunds for periods before October 9, 2018, was held invalid and without jurisdiction. The ruling aligned with previous rectification order in Cosmo Films Limited case which corrected the earlier misinterpretation regarding notification's effective date. The decision establishes clear temporal boundaries for enforcement of amended Rule 96(10).
HC determined that Notification No. 54/2018-Central Tax amending Rule 96(10) of CGST Rules operates prospectively from October 9, 2018, not retrospectively from October 23, 2017. The court quashed summons, notices, and recovery proceedings initiated based on retrospective application of the notification. Any quantification of alleged erroneous refunds for periods before October 9, 2018, was held invalid and without jurisdiction. The ruling aligned with previous rectification order in Cosmo Films Limited case which corrected the earlier misinterpretation regarding notification's effective date. The decision establishes clear temporal boundaries for enforcement of amended Rule 96(10).
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