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...
Electrical installations and their components for factory expansion do not qualify as 'plant and machinery' under the Explanation to Section 17(5) of the CGST Act because they are generic, serve multiple functions, and upon annexation become part of immovable property; consequence: input tax credit on GST paid for such electrical works is disallowed under the blocking provisions of Section 17(5). Because ITC is denied on the merits, issues concerning timing or basis to claim ITC for supplier invoices treating amounts as advances and subsequent adjustments were deemed inapplicable and were not considered further.
Electrical installations and their components for factory expansion do not qualify as 'plant and machinery' under the Explanation to Section 17(5) of the CGST Act because they are generic, serve multiple functions, and upon annexation become part of immovable property; consequence: input tax credit on GST paid for such electrical works is disallowed under the blocking provisions of Section 17(5). Because ITC is denied on the merits, issues concerning timing or basis to claim ITC for supplier invoices treating amounts as advances and subsequent adjustments were deemed inapplicable and were not considered further.
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