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 held that amendments to CGST and KGST Acts regarding deemed supply of services by clubs/associations to members are unconstitutional. The court determined that the principle of mutuality survives constitutional interpretation, and the retrospective amendments violate the Rule of Law. The statutory provisions improperly expanded the definition of "supply" and "service" without constitutional basis. The amendments were declared void, with the court emphasizing that legislative actions must respect fairness and cannot impose unexpected tax liabilities retrospectively. The judgment upholds the principle that taxation mechanisms cannot arbitrarily redefine fundamental legal concepts without appropriate constitutional amendments.
HC held that amendments to CGST and KGST Acts regarding deemed supply of services by clubs/associations to members are unconstitutional. The court determined that the principle of mutuality survives constitutional interpretation, and the retrospective amendments violate the Rule of Law. The statutory provisions improperly expanded the definition of "supply" and "service" without constitutional basis. The amendments were declared void, with the court emphasizing that legislative actions must respect fairness and cannot impose unexpected tax liabilities retrospectively. The judgment upholds the principle that taxation mechanisms cannot arbitrarily redefine fundamental legal concepts without appropriate constitutional amendments.
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