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...
Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.
Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
