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 SC allowed the appeal and restored the petition to the HC, directing it to adjudicate afresh in line with the precedent set in M/s Safari Retreats Pvt Ltd. The HC had previously denied ITC on the breakwater, holding it was not "plant and machinery" used for outward supply. The SC's order implies reconsideration of ITC eligibility regarding the breakwater's classification and its use in supply chain activities.
The SC allowed the appeal and restored the petition to the HC, directing it to adjudicate afresh in line with the precedent set in M/s Safari Retreats Pvt Ltd. The HC had previously denied ITC on the breakwater, holding it was not "plant and machinery" used for outward supply. The SC's order implies reconsideration of ITC eligibility regarding the breakwater's classification and its use in supply chain activities.
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