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...
The AAR ruled that goods supplied by the applicant, despite being a victim of fraud without receiving consideration, still constituted a "supply" under GST law. The authority determined that while fraud may vitiate a contract, it does not negate the statutory definition of "supply" under section 7 of the CGST Act. The facts established that goods were physically removed and received at the destination, as confirmed by the FIR. The AAR concluded that the transaction qualified as supply of goods under section 20 of the IGST Act read with sections 12 and 7 of the CGST Act, regardless of the fraudulent nature of the order.
The AAR ruled that goods supplied by the applicant, despite being a victim of fraud without receiving consideration, still constituted a "supply" under GST law. The authority determined that while fraud may vitiate a contract, it does not negate the statutory definition of "supply" under section 7 of the CGST Act. The facts established that goods were physically removed and received at the destination, as confirmed by the FIR. The AAR concluded that the transaction qualified as supply of goods under section 20 of the IGST Act read with sections 12 and 7 of the CGST Act, regardless of the fraudulent nature of the order.
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