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...
Fees charged by an electricity regulatory commission for discharging statutory, quasi judicial and regulatory functions do not constitute a taxable supply in the course or furtherance of business because the definitions of 'consideration' and 'business' must be read together under the GST scheme. The analysis adopts precedent finding that regulatory/tribunal like activities are not commercial trade or inducements for supply, and Schedule III excludes services rendered by courts or tribunals. Applying these principles the impugned show cause notice levying GST on tariff petition and licence fees was arbitrary and was quashed; the writ petition succeeds.
Fees charged by an electricity regulatory commission for discharging statutory, quasi judicial and regulatory functions do not constitute a taxable supply in the course or furtherance of business because the definitions of 'consideration' and 'business' must be read together under the GST scheme. The analysis adopts precedent finding that regulatory/tribunal like activities are not commercial trade or inducements for supply, and Schedule III excludes services rendered by courts or tribunals. Applying these principles the impugned show cause notice levying GST on tariff petition and licence fees was arbitrary and was quashed; the writ petition succeeds.
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