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...
AAR held that proportionate refund received by the applicant upon cancellation of a pre-GST lease agreement is not taxable under GST. While property leasing constitutes supply of service, lease cancellation itself does not constitute taxable activity under CGST Act. Relying on CBIC Circular No. 178/10/2022-GST regarding coal block cancellation compensation, AAR determined that refund for unexpired lease period does not involve any supply of service as defined under Section 7 of CGST Act, 2017. The transaction merely constitutes return of consideration for unutilized period rather than agreement to perform, refrain from, or tolerate any act, thus falling outside GST liability.
AAR held that proportionate refund received by the applicant upon cancellation of a pre-GST lease agreement is not taxable under GST. While property leasing constitutes supply of service, lease cancellation itself does not constitute taxable activity under CGST Act. Relying on CBIC Circular No. 178/10/2022-GST regarding coal block cancellation compensation, AAR determined that refund for unexpired lease period does not involve any supply of service as defined under Section 7 of CGST Act, 2017. The transaction merely constitutes return of consideration for unutilized period rather than agreement to perform, refrain from, or tolerate any act, thus falling outside GST liability.
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