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...
A pyjama set comprising a top and bottom sold together qualifies as a single piece for classification under the relevant notifications; a pack containing two such sets therefore comprises two pieces and cannot be treated as a single retail unit. The GST rate must be determined by sale value per piece by apportioning the pack price to each set; where the apportioned per-piece price falls below the notification threshold the lower rate applies. The subsequent amendment raising the threshold (effective 22.09.2025) is consistent with this per-piece approach. The AAR decision applying this method was upheld on the facts.
A pyjama set comprising a top and bottom sold together qualifies as a single piece for classification under the relevant notifications; a pack containing two such sets therefore comprises two pieces and cannot be treated as a single retail unit. The GST rate must be determined by sale value per piece by apportioning the pack price to each set; where the apportioned per-piece price falls below the notification threshold the lower rate applies. The subsequent amendment raising the threshold (effective 22.09.2025) is consistent with this per-piece approach. The AAR decision applying this method was upheld on the facts.
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