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...
A statutory religious body was treated as a body corporate engaged in business for GST purposes, and auctioning or tendering exclusive rights was characterised as a licensing arrangement and therefore a supply of services. GST was held payable on rights to collect offering-remnants and abandoned clothes, to perform rituals, and to operate toilets and washrooms, because the applicant was not itself supplying those services but granting commercial rights for consideration. Exemption was recognised for rights to harvest coconuts from temple lands as a service linked to agricultural operations, and for pooja item stalls as renting of precincts of a religious place, subject to notification conditions. Reverse charge did not apply to honorarium or sitting fees paid to the President and Members, but applied to legal services from advocates.
A statutory religious body was treated as a body corporate engaged in business for GST purposes, and auctioning or tendering exclusive rights was characterised as a licensing arrangement and therefore a supply of services. GST was held payable on rights to collect offering-remnants and abandoned clothes, to perform rituals, and to operate toilets and washrooms, because the applicant was not itself supplying those services but granting commercial rights for consideration. Exemption was recognised for rights to harvest coconuts from temple lands as a service linked to agricultural operations, and for pooja item stalls as renting of precincts of a religious place, subject to notification conditions. Reverse charge did not apply to honorarium or sitting fees paid to the President and Members, but applied to legal services from advocates.
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