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 challenge to the rejection of ITC claim, finding a procedural error in the original orders. The court determined that physical movement of goods is not the sole criterion for ITC eligibility. The matter was remanded to the Deputy Commissioner to re-examine the case, specifically focusing on verifying the memorandum of understanding between the dealer and supplier, and assessing the documentation related to goods delivery. The court directed a fresh review of the ITC claim under Section 16(2)(b) of CGST Act, emphasizing the need for comprehensive examination of transaction details and supporting evidence.
HC allowed the petitioner's challenge to the rejection of ITC claim, finding a procedural error in the original orders. The court determined that physical movement of goods is not the sole criterion for ITC eligibility. The matter was remanded to the Deputy Commissioner to re-examine the case, specifically focusing on verifying the memorandum of understanding between the dealer and supplier, and assessing the documentation related to goods delivery. The court directed a fresh review of the ITC claim under Section 16(2)(b) of CGST Act, emphasizing the need for comprehensive examination of transaction details and supporting evidence.
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