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...
Assignment of long-term (95-year) leasehold rights that extinguishes the transferor's rights and vests benefits in an assignee constitutes a transfer of benefits arising out of immovable property, not a supply of services under the GST supply framework; accordingly, classification of such assignment as 'other miscellaneous services' taxable at 18% was legally unsustainable and a show cause notice premised on that classification was quashed. The decision emphasises absence of nexus with the transferor's business and the character of the long term lease as determinative of tax treatment.
Assignment of long-term (95-year) leasehold rights that extinguishes the transferor's rights and vests benefits in an assignee constitutes a transfer of benefits arising out of immovable property, not a supply of services under the GST supply framework; accordingly, classification of such assignment as 'other miscellaneous services' taxable at 18% was legally unsustainable and a show cause notice premised on that classification was quashed. The decision emphasises absence of nexus with the transferor's business and the character of the long term lease as determinative of tax treatment.
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