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 directed the Respondent Department to re-credit the Petitioner's Input Tax Credit (ITC) of Rs. 23,32,278/- to the Petitioner's Electronic Credit Ledger within four weeks, permitting manual intervention if necessary, upon finding no dispute as to entitlement and that non-credit arose solely from a technical limitation of the GST portal preventing issuance of PMT-03. The court held that the refund cannot be withheld on account of the technical impediment and ordered immediate compliance with the re-crediting directive. The petition is disposed of accordingly.
The HC directed the Respondent Department to re-credit the Petitioner's Input Tax Credit (ITC) of Rs. 23,32,278/- to the Petitioner's Electronic Credit Ledger within four weeks, permitting manual intervention if necessary, upon finding no dispute as to entitlement and that non-credit arose solely from a technical limitation of the GST portal preventing issuance of PMT-03. The court held that the refund cannot be withheld on account of the technical impediment and ordered immediate compliance with the re-crediting directive. The petition is disposed of accordingly.
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