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 determined that supplies by petitioner outside customs frontiers qualify as zero-rated under Section 16 of IGST Act, rendering the transaction GST-exempt. The court found the tax treatment revenue neutral, particularly for the period before 01.04.2021, and declined revenue's challenge. The third-party refund application must be processed within four weeks, including applicable interest, effectively disposing of the appeal without substantial monetary implications for either party.
HC determined that supplies by petitioner outside customs frontiers qualify as zero-rated under Section 16 of IGST Act, rendering the transaction GST-exempt. The court found the tax treatment revenue neutral, particularly for the period before 01.04.2021, and declined revenue's challenge. The third-party refund application must be processed within four weeks, including applicable interest, effectively disposing of the appeal without substantial monetary implications for either party.
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