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...
Denial and reversal of input tax credit solely on the ground of limitation under Section 16(4) of the CGST Act was challenged. The Court held that, in view of the retrospective insertion of Section 16(5) with effect from 01.07.2017, ITC cannot be denied where the claim was otherwise time-barred under Section 16(4) but fell within the extended period under Section 16(5) for relevant financial years, including where GSTR-3B was filed on or before 30.11.2021. Consequently, the impugned order was quashed to that extent, the department was restrained from initiating limitation-based proceedings, and the matter was remanded. - HC
Denial and reversal of input tax credit solely on the ground of limitation under Section 16(4) of the CGST Act was challenged. The Court held that, in view of the retrospective insertion of Section 16(5) with effect from 01.07.2017, ITC cannot be denied where the claim was otherwise time-barred under Section 16(4) but fell within the extended period under Section 16(5) for relevant financial years, including where GSTR-3B was filed on or before 30.11.2021. Consequently, the impugned order was quashed to that extent, the department was restrained from initiating limitation-based proceedings, and the matter was remanded. - HC
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