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 allowed petition challenging service tax penalties under CGST Act. Penalties pertained to period before CGST implementation when services were exempt under Finance Act 1994. Court relied on precedent from Kanak Automobiles case where tax amount was Rs. 86 lakh compared to present case's Rs. 6,33,879. Distinguishing quantum while following ratio from SC judgment, court found penalties inapplicable since services were exempt during relevant period and CGST provisions could not be applied retrospectively.
HC allowed petition challenging service tax penalties under CGST Act. Penalties pertained to period before CGST implementation when services were exempt under Finance Act 1994. Court relied on precedent from Kanak Automobiles case where tax amount was Rs. 86 lakh compared to present case's Rs. 6,33,879. Distinguishing quantum while following ratio from SC judgment, court found penalties inapplicable since services were exempt during relevant period and CGST provisions could not be applied retrospectively.
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