Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
HC adjudicated a GST refund claim involving services rendered by a foreign affiliate to a domestic related entity. The court referenced precedential judgments in Thales India Pvt. Ltd. and Metal One Corporation Pvt. Ltd., which addressed similar legal controversies regarding service valuation under CBIC Circular No. 210/4/2024. The Department conceded no challenge to the prior order, resulting in the court directing full refund processing of Rs. 8,99,61,147/- to be credited within two months. The petition was consequently disposed of, affirming the petitioner's entitlement to the claimed refund amount.
HC adjudicated a GST refund claim involving services rendered by a foreign affiliate to a domestic related entity. The court referenced precedential judgments in Thales India Pvt. Ltd. and Metal One Corporation Pvt. Ltd., which addressed similar legal controversies regarding service valuation under CBIC Circular No. 210/4/2024. The Department conceded no challenge to the prior order, resulting in the court directing full refund processing of Rs. 8,99,61,147/- to be credited within two months. The petition was consequently disposed of, affirming the petitioner's entitlement to the claimed refund amount.
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