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 petitioner's challenge regarding CENVAT credit utilization, affirming that input tax credit electronic ledger represents a unified wallet with compartments for IGST, CGST, and SGST. The court referenced prior precedent emphasizing that tax credit eligibility should be assessed based on total wallet balance, not individual compartments. The 3rd respondent was directed to issue fresh orders within two months, consistent with the judicial interpretation, effectively resolving the inadvertent tax credit mismatch between GSTR 3B and GSTR 2A forms.
HC allowed petitioner's challenge regarding CENVAT credit utilization, affirming that input tax credit electronic ledger represents a unified wallet with compartments for IGST, CGST, and SGST. The court referenced prior precedent emphasizing that tax credit eligibility should be assessed based on total wallet balance, not individual compartments. The 3rd respondent was directed to issue fresh orders within two months, consistent with the judicial interpretation, effectively resolving the inadvertent tax credit mismatch between GSTR 3B and GSTR 2A forms.
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