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 holographic stickers supplied by the Prohibition and Excise Department constitute "goods" under Section 2(52) of GST laws, not services. The supply cannot be classified as a "composite supply" with excise licensing. The petitioner's previous RCM tax payments were made erroneously, as the stickers are not taxable supplies under Section 2(108). The court rejected the respondents' estoppel argument, affirming that tax principles are not bound by past practices. The second respondent must process refund claims under Section 54 of GST Acts and Rule 89 of GST rules within 3 months. The petition was allowed, granting refund of GST paid under reverse charge mechanism for holographic sticker procurement.
HC determined that holographic stickers supplied by the Prohibition and Excise Department constitute "goods" under Section 2(52) of GST laws, not services. The supply cannot be classified as a "composite supply" with excise licensing. The petitioner's previous RCM tax payments were made erroneously, as the stickers are not taxable supplies under Section 2(108). The court rejected the respondents' estoppel argument, affirming that tax principles are not bound by past practices. The second respondent must process refund claims under Section 54 of GST Acts and Rule 89 of GST rules within 3 months. The petition was allowed, granting refund of GST paid under reverse charge mechanism for holographic sticker procurement.
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