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...
Writ challenges to licence notices and tender conditions became infructuous after the licence period expired, so no effective relief could be granted on those issues. GST demands raised under reverse charge on 99% of the licence fee were unsustainable because TASMAC is a distinct juristic entity and not the State Government, Union Territory or local authority for the relevant notifications; the reverse charge entry therefore did not apply. The assessment orders and show cause notice on that basis were quashed. The Court left open independent GST liability, if any, on the petitioners' own supplies and permitted fresh proceedings under the machinery for unregistered persons, subject to limitation.
Writ challenges to licence notices and tender conditions became infructuous after the licence period expired, so no effective relief could be granted on those issues. GST demands raised under reverse charge on 99% of the licence fee were unsustainable because TASMAC is a distinct juristic entity and not the State Government, Union Territory or local authority for the relevant notifications; the reverse charge entry therefore did not apply. The assessment orders and show cause notice on that basis were quashed. The Court left open independent GST liability, if any, on the petitioners' own supplies and permitted fresh proceedings under the machinery for unregistered persons, subject to limitation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
