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...
GST collected on the sale of rejected wheat and paddy seeds was treated as refundable because GST was not payable on those transactions, and that foundational position was not disputed. The Court held that the department could not continue retaining the tax merely because the refund had not yet been processed. It also required compliance with Rule 89 by directing the Corporation to file the refund claim in Form RFD-01, after which the department was to refund the amount forthwith for onward payment to the petitioner by the Corporation.
GST collected on the sale of rejected wheat and paddy seeds was treated as refundable because GST was not payable on those transactions, and that foundational position was not disputed. The Court held that the department could not continue retaining the tax merely because the refund had not yet been processed. It also required compliance with Rule 89 by directing the Corporation to file the refund claim in Form RFD-01, after which the department was to refund the amount forthwith for onward payment to the petitioner by the Corporation.
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