Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The AT held that, following consideration of the DGAP report and documentary verification, the DGAP's methodology for apportioning ITC to project costs was appropriate and captured the economic effect of GST implementation. The Tribunal found that no reduction in GST rate nor incremental benefit of Input Tax Credit accrued to the Respondent in respect of the three impugned projects; accordingly, the requirements of Section 171 of the CGST Act are not attracted. Proceedings against the Respondent in relation to those projects were dismissed and the application disposed of.
The AT held that, following consideration of the DGAP report and documentary verification, the DGAP's methodology for apportioning ITC to project costs was appropriate and captured the economic effect of GST implementation. The Tribunal found that no reduction in GST rate nor incremental benefit of Input Tax Credit accrued to the Respondent in respect of the three impugned projects; accordingly, the requirements of Section 171 of the CGST Act are not attracted. Proceedings against the Respondent in relation to those projects were dismissed and the application disposed of.
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