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...
Section 16(5), as inserted retrospectively from 01.07.2017, extends and overrides the time limit under Section 16(4) for claiming input tax credit for financial years 2017 18 to 2020 21, so returns filed within the extended cut off are not barred merely by the earlier time limit; orders denying ITC solely on that time bar were set aside. The matter is remitted to the assessing authority to determine factual eligibility for the claimed ITC, permitting factual reassessment but not re-opening the legal conclusion on the extended time limit.
Section 16(5), as inserted retrospectively from 01.07.2017, extends and overrides the time limit under Section 16(4) for claiming input tax credit for financial years 2017 18 to 2020 21, so returns filed within the extended cut off are not barred merely by the earlier time limit; orders denying ITC solely on that time bar were set aside. The matter is remitted to the assessing authority to determine factual eligibility for the claimed ITC, permitting factual reassessment but not re-opening the legal conclusion on the extended time limit.
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