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...
A central tax policy instruction directs uniform implementation permitting provisional sanction of 90% of refund claims for system-identified low-risk applications relating to zero-rated supplies, and temporarily for inverted duty structure claims, effective for claims filed on or after 01.10.2025; officers may, with reasons recorded, opt for detailed scrutiny instead of provisional grant, and certain notified categories remain ineligible for provisional refunds. Statutory conditions (including non-prosecution requirements) continue to apply; overpayments discovered on verification will prompt show-cause proceedings and recovery. Jurisdictional supervising officers must monitor implementation and report difficulties to the Board.
A central tax policy instruction directs uniform implementation permitting provisional sanction of 90% of refund claims for system-identified low-risk applications relating to zero-rated supplies, and temporarily for inverted duty structure claims, effective for claims filed on or after 01.10.2025; officers may, with reasons recorded, opt for detailed scrutiny instead of provisional grant, and certain notified categories remain ineligible for provisional refunds. Statutory conditions (including non-prosecution requirements) continue to apply; overpayments discovered on verification will prompt show-cause proceedings and recovery. Jurisdictional supervising officers must monitor implementation and report difficulties to the Board.
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