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 set aside tax liability determination under section 73 of CGST Act, 2017 and remanded for fresh consideration. The case involved ITC claims related to construction of shopping malls. Following Safari Retreats precedent, court held that 'plant or machinery' interpretation under section 17(5)(d) requires factual determination based on business context. Original order failed to consider Safari Retreats principles regarding classification of malls as plant. Issues regarding 8 invoices and ITC reporting discrepancies between GSTR-3B and GSTR-9 forms remain open for fresh examination. Matter remanded for de novo consideration incorporating Supreme Court's interpretative guidance.
HC set aside tax liability determination under section 73 of CGST Act, 2017 and remanded for fresh consideration. The case involved ITC claims related to construction of shopping malls. Following Safari Retreats precedent, court held that 'plant or machinery' interpretation under section 17(5)(d) requires factual determination based on business context. Original order failed to consider Safari Retreats principles regarding classification of malls as plant. Issues regarding 8 invoices and ITC reporting discrepancies between GSTR-3B and GSTR-9 forms remain open for fresh examination. Matter remanded for de novo consideration incorporating Supreme Court's interpretative guidance.
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