Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
The HC set aside the impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
The HC set aside the impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
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