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...
Challenge concerns taxability of ocean freight under the IGST reverse charge mechanism and rejection of a rectification application. The court found the Proper Officer erred in treating a Supreme Court decision as prospective where constitutional precedent requires judgments to operate retrospectively unless expressly prospective, and concluded the SC ruling that Notification 10/2017 is clarificatory (not altering the taxable person under reverse charge) governs earlier import transactions; therefore the impugned confirmation of IGST demand and the March 25, 2025 rejection of rectification could not be sustained and the rectification application was allowed.
Challenge concerns taxability of ocean freight under the IGST reverse charge mechanism and rejection of a rectification application. The court found the Proper Officer erred in treating a Supreme Court decision as prospective where constitutional precedent requires judgments to operate retrospectively unless expressly prospective, and concluded the SC ruling that Notification 10/2017 is clarificatory (not altering the taxable person under reverse charge) governs earlier import transactions; therefore the impugned confirmation of IGST demand and the March 25, 2025 rejection of rectification could not be sustained and the rectification application was allowed.
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