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...
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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