Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
HC declared amendments to CGST and KGST Acts unconstitutional, finding retrospective modifications ultra vires the Constitution. The court held that legislative amendments improperly expanded the definition of "supply" and "service" by disregarding the principle of mutuality. The retrospective taxation violated fundamental principles of fairness and Rule of Law, as it imposed unexpected tax burdens on entities without prior notice or opportunity to adjust. The amendments were deemed void, emphasizing constitutional limitations on legislative power to redefine taxation principles retroactively. The judgment reinforced constitutional protections against arbitrary legislative interventions in taxation frameworks.
HC declared amendments to CGST and KGST Acts unconstitutional, finding retrospective modifications ultra vires the Constitution. The court held that legislative amendments improperly expanded the definition of "supply" and "service" by disregarding the principle of mutuality. The retrospective taxation violated fundamental principles of fairness and Rule of Law, as it imposed unexpected tax burdens on entities without prior notice or opportunity to adjust. The amendments were deemed void, emphasizing constitutional limitations on legislative power to redefine taxation principles retroactively. The judgment reinforced constitutional protections against arbitrary legislative interventions in taxation frameworks.
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