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...
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
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