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 held that the impugned IGST levy on ocean freight under the reverse-charge notifications was ultra vires and contrary to the GST scheme, requiring refund of Rs. 2,62,37,558 paid by the Petitioner; the Respondents have refunded that amount. The petition further succeeded in claiming interest of Rs. 71,31,225, which the HC directed the Respondents to pay forthwith and in any event within four weeks of judgment. The court clarified that Sections 54/56 were inapplicable to the initial unlawful collection, but nonetheless sanctioned the quantified interest on the merits. Petition disposed.
The HC held that the impugned IGST levy on ocean freight under the reverse-charge notifications was ultra vires and contrary to the GST scheme, requiring refund of Rs. 2,62,37,558 paid by the Petitioner; the Respondents have refunded that amount. The petition further succeeded in claiming interest of Rs. 71,31,225, which the HC directed the Respondents to pay forthwith and in any event within four weeks of judgment. The court clarified that Sections 54/56 were inapplicable to the initial unlawful collection, but nonetheless sanctioned the quantified interest on the merits. Petition disposed.
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