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...
State universities collecting affiliation fees and no-objection certificate fees were held not to make a taxable supply under GST because their affiliation and NOC functions were mandatory statutory duties, not voluntary commercial activity carried on in the course or furtherance of business. The Court distinguished the universities from the State Government and local authorities, and applied the definition of business in Section 2(17) to conclude that such receipts did not fall within Section 7. The GST assessment orders on those fees were therefore set aside, and the exemption notifications were not examined.
State universities collecting affiliation fees and no-objection certificate fees were held not to make a taxable supply under GST because their affiliation and NOC functions were mandatory statutory duties, not voluntary commercial activity carried on in the course or furtherance of business. The Court distinguished the universities from the State Government and local authorities, and applied the definition of business in Section 2(17) to conclude that such receipts did not fall within Section 7. The GST assessment orders on those fees were therefore set aside, and the exemption notifications were not examined.
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