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 AAAR dismissed the appeal and held that import IGST paid via TR-6 challan is not an admissible document for claiming ITC because a TR-6 is a Treasury payment instrument and not a "bill of entry or any similar document" prescribed under the Customs Act or rules; consequently TR-6 (alone or read with SVB orders/letters) cannot support ITC. A re-assessed bill of entry, however, constitutes a prescribed document under r.36(1)(d) and thus may permit ITC, but such availment is governed by the time-bar in s.16(4) CGST, applied to IGST claims by s.20 IGST Act mutatis mutandis. Appeal dismissed.
The AAAR dismissed the appeal and held that import IGST paid via TR-6 challan is not an admissible document for claiming ITC because a TR-6 is a Treasury payment instrument and not a "bill of entry or any similar document" prescribed under the Customs Act or rules; consequently TR-6 (alone or read with SVB orders/letters) cannot support ITC. A re-assessed bill of entry, however, constitutes a prescribed document under r.36(1)(d) and thus may permit ITC, but such availment is governed by the time-bar in s.16(4) CGST, applied to IGST claims by s.20 IGST Act mutatis mutandis. Appeal dismissed.
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