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 the petitioner is not an "intermediary" under IGST Act, Section 13(8) and Section 2(13). Based on an identical CESTAT order that had attained finality and CBIC Circular clarifying service tax and GST intermediary provisions, the court found no basis to differentiate the petitioner's case. The court remanded the matter to the adjudicating authority to process the refund claim with applicable interest within 4 weeks, effectively allowing the petitioner's claim for IGST refund.
HC determined that the petitioner is not an "intermediary" under IGST Act, Section 13(8) and Section 2(13). Based on an identical CESTAT order that had attained finality and CBIC Circular clarifying service tax and GST intermediary provisions, the court found no basis to differentiate the petitioner's case. The court remanded the matter to the adjudicating authority to process the refund claim with applicable interest within 4 weeks, effectively allowing the petitioner's claim for IGST refund.
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