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 petition, directing re-adjudication of ITC refund claims for February 2021 to February 2022. The court held that Notification No. 14/2022 is clarificatory and applies retroactively to all refund claims filed within two-year limitation under GST Act. The key directive mandates Respondent No. 2 to reassess refund applications within 12 weeks using amended Rule 89(5), ensuring petitioners receive legitimate refund without unjust governmental enrichment.
HC allowed the petition, directing re-adjudication of ITC refund claims for February 2021 to February 2022. The court held that Notification No. 14/2022 is clarificatory and applies retroactively to all refund claims filed within two-year limitation under GST Act. The key directive mandates Respondent No. 2 to reassess refund applications within 12 weeks using amended Rule 89(5), ensuring petitioners receive legitimate refund without unjust governmental enrichment.
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