Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The AT dismissed the DGAP's profiteering report and closed proceedings against the Respondent under Section 171, CGST Act, holding there is no admissible material establishing that the Respondent retained an unlawful benefit of input tax credit by failing to reduce prices. The AT noted mixed SKU price movements and absence of document evidence demonstrating overall profiteering; enquiries of 56 recipients showed 50 received ITC-related benefit, one was unregistered, and five were unreachable due to closure/liquidation/death. Consequently the DGAP's concluded profiteering amount was not accepted, no liability was fastened on the Respondent, and the complaint was thereby disposed.
The AT dismissed the DGAP's profiteering report and closed proceedings against the Respondent under Section 171, CGST Act, holding there is no admissible material establishing that the Respondent retained an unlawful benefit of input tax credit by failing to reduce prices. The AT noted mixed SKU price movements and absence of document evidence demonstrating overall profiteering; enquiries of 56 recipients showed 50 received ITC-related benefit, one was unregistered, and five were unreachable due to closure/liquidation/death. Consequently the DGAP's concluded profiteering amount was not accepted, no liability was fastened on the Respondent, and the complaint was thereby disposed.
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