Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Refund claims under GST could not be rejected without examining the governing agreement that defined the service arrangement. The High Court found that the appellate authority had not recorded findings on whether the supplies were export of services or intermediary services, even though that characterisation was central to the claim for zero-rated treatment under the IGST Act. As the agreement was foundational to determining the nature of the services, the impugned appellate orders were unsustainable. The orders were quashed and the refund proceedings remanded to the appellate authority for fresh consideration after hearing the parties, with all contentions kept open.
Refund claims under GST could not be rejected without examining the governing agreement that defined the service arrangement. The High Court found that the appellate authority had not recorded findings on whether the supplies were export of services or intermediary services, even though that characterisation was central to the claim for zero-rated treatment under the IGST Act. As the agreement was foundational to determining the nature of the services, the impugned appellate orders were unsustainable. The orders were quashed and the refund proceedings remanded to the appellate authority for fresh consideration after hearing the parties, with all contentions kept open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
