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...
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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