Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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Whether services treated as local supply could be reclassified as export by denying refund on the ground that the claimant was an "intermediary" under GST law was the dominant issue. On examining the record and applying settled principles on intermediary services, it was held that the claimant was not an intermediary and the services qualified as export, entitling it to refund of accumulated/unutilized ITC. Consequently, the refund rejection orders were quashed and the authorities were directed to sanction the refund with applicable interest within three months; the matter was remanded for consequential compliance. - HC
Whether services treated as local supply could be reclassified as export by denying refund on the ground that the claimant was an "intermediary" under GST law was the dominant issue. On examining the record and applying settled principles on intermediary services, it was held that the claimant was not an intermediary and the services qualified as export, entitling it to refund of accumulated/unutilized ITC. Consequently, the refund rejection orders were quashed and the authorities were directed to sanction the refund with applicable interest within three months; the matter was remanded for consequential compliance. - HC
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