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 the petitioner's refund claim, holding that the rejection of Rs. 2,195/- by the respondent was improper and contrary to the budgetary support scheme notification. The court determined that the petitioner was entitled to budgetary support calculated at 58% of central tax paid through cash ledger and 29% of IGST paid, after input tax credit utilization. The HC directed the respondent to release the inadmissible amount for the quarter January 2022 to March 2022, finding no justification for the partial claim rejection.
HC allowed the petitioner's refund claim, holding that the rejection of Rs. 2,195/- by the respondent was improper and contrary to the budgetary support scheme notification. The court determined that the petitioner was entitled to budgetary support calculated at 58% of central tax paid through cash ledger and 29% of IGST paid, after input tax credit utilization. The HC directed the respondent to release the inadmissible amount for the quarter January 2022 to March 2022, finding no justification for the partial claim rejection.
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