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 held that the petitioner's contract falls under category B, not category D, for GST purposes, as it pertains to works sanctioned post 01.07.2017 under PMGSY phases without GST accounted in the original sanction. The respondent authority failed to follow the prescribed procedure under category A, which is applicable to category B cases, including the reverse charge mechanism for GST on running bills paid from 01.07.2017. The Court directed the respondent to strictly adhere to the procedure outlined in the communication dated 06.06.2018 and to refund the 2% GST amount previously deducted from the petitioner. The respondent must complete these steps within three months from receipt of the certified order. The writ petition was allowed accordingly.
The HC held that the petitioner's contract falls under category B, not category D, for GST purposes, as it pertains to works sanctioned post 01.07.2017 under PMGSY phases without GST accounted in the original sanction. The respondent authority failed to follow the prescribed procedure under category A, which is applicable to category B cases, including the reverse charge mechanism for GST on running bills paid from 01.07.2017. The Court directed the respondent to strictly adhere to the procedure outlined in the communication dated 06.06.2018 and to refund the 2% GST amount previously deducted from the petitioner. The respondent must complete these steps within three months from receipt of the certified order. The writ petition was allowed accordingly.
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