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 appeal, setting aside the previous order and judgment regarding budgetary support claims. The court held that claims for reimbursement under the Jammu & Kashmir GST scheme shall be calculated and filed on a quarterly basis, covering periods of January-March, April-June, July-September, and October-December. The departmental clarification dated 26-04-2022 was deemed valid, rejecting the respondents' argument that a subsequent DPIIT clarification should supersede the HC's directive. The ruling enables manufacturing units to seek tax reimbursement by aggregating tax liabilities and input tax credits on a quarterly basis, providing a clear mechanism for budgetary support claims.
HC allowed the appeal, setting aside the previous order and judgment regarding budgetary support claims. The court held that claims for reimbursement under the Jammu & Kashmir GST scheme shall be calculated and filed on a quarterly basis, covering periods of January-March, April-June, July-September, and October-December. The departmental clarification dated 26-04-2022 was deemed valid, rejecting the respondents' argument that a subsequent DPIIT clarification should supersede the HC's directive. The ruling enables manufacturing units to seek tax reimbursement by aggregating tax liabilities and input tax credits on a quarterly basis, providing a clear mechanism for budgetary support claims.
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