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...
Refund rejection orders concerning unutilised input tax credit of compensation cess on zero-rated supplies were not sustained because the controversy was identical to that already decided in the assessee's own case. Applying the earlier Division Bench decision, the HC directed reconsideration by the original authority in accordance with law after granting an opportunity of hearing. The refund matters were thus remanded for fresh decision within four months, and the impugned rejection orders were set aside for that limited purpose.
Refund rejection orders concerning unutilised input tax credit of compensation cess on zero-rated supplies were not sustained because the controversy was identical to that already decided in the assessee's own case. Applying the earlier Division Bench decision, the HC directed reconsideration by the original authority in accordance with law after granting an opportunity of hearing. The refund matters were thus remanded for fresh decision within four months, and the impugned rejection orders were set aside for that limited purpose.
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