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 an independent service provider, not an intermediary under IGST Act. Services rendered to overseas recipients constitute export of services exempt from GST liability. The court quashed the appellate authority's order dated 01.09.2023, restored the original order dated 28.07.2022 granting refund for April and May 2022, and held that refund claims under Section 54 of CGST Act are maintainable and not time-barred. The petition was consequently allowed, affirming the petitioner's right to claim GST refund.
HC determined that the petitioner is an independent service provider, not an intermediary under IGST Act. Services rendered to overseas recipients constitute export of services exempt from GST liability. The court quashed the appellate authority's order dated 01.09.2023, restored the original order dated 28.07.2022 granting refund for April and May 2022, and held that refund claims under Section 54 of CGST Act are maintainable and not time-barred. The petition was consequently allowed, affirming the petitioner's right to claim GST refund.
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