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...
The HC ruled that assignment of leasehold rights in immovable property allotted by a government industrial development corporation does not constitute taxable supply under GST. Following precedent established in Gujarat Chamber of Commerce and subsequent decisions including Alfa Tools Pvt. Ltd., BVM Pharma, and Time Technoplast Limited, the court held that such assignments are exempt from GST liability. Additionally, transfer from partnership to sole proprietorship was deemed internal reorganization exempt from GST. The court quashed impugned orders demanding GST, interest, and penalty, allowing the petition and setting aside the contested orders.
The HC ruled that assignment of leasehold rights in immovable property allotted by a government industrial development corporation does not constitute taxable supply under GST. Following precedent established in Gujarat Chamber of Commerce and subsequent decisions including Alfa Tools Pvt. Ltd., BVM Pharma, and Time Technoplast Limited, the court held that such assignments are exempt from GST liability. Additionally, transfer from partnership to sole proprietorship was deemed internal reorganization exempt from GST. The court quashed impugned orders demanding GST, interest, and penalty, allowing the petition and setting aside the contested orders.
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