Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
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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