Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The HC quashed an order denying refund of unutilized Input Tax Credit for FY 2022-23 and Q1 of FY 2023-24. The respondent had rejected the refund claim because payments for exported services by petitioner's Delhi branch office were remitted to a bank account in Bangalore. Relying on Cable and Wireless Global India Private Limited, the Court held that mapping a Bangalore bank account after receiving remittances validates that services were exported by the Delhi branch office. The Court found the respondent's objection overly technical and unsustainable, ruling that remittance to a Bangalore bank account does not preclude refund eligibility. The petitioner's claim was remanded for reconsideration.
The HC quashed an order denying refund of unutilized Input Tax Credit for FY 2022-23 and Q1 of FY 2023-24. The respondent had rejected the refund claim because payments for exported services by petitioner's Delhi branch office were remitted to a bank account in Bangalore. Relying on Cable and Wireless Global India Private Limited, the Court held that mapping a Bangalore bank account after receiving remittances validates that services were exported by the Delhi branch office. The Court found the respondent's objection overly technical and unsustainable, ruling that remittance to a Bangalore bank account does not preclude refund eligibility. The petitioner's claim was remanded for reconsideration.
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