Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
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Omission of Rule 96(10) of the CGST Rules, without a saving or sunset clause, ends the export-refund restriction for pending proceedings concerning integrated tax paid on exported goods and services. Applying the principle that an omitted provision cannot be kept alive without express preservation, communications founded on the former restriction cannot sustain denial of such refunds.
Omission of Rule 96(10) of the CGST Rules, without a saving or sunset clause, ends the export-refund restriction for pending proceedings concerning integrated tax paid on exported goods and services. Applying the principle that an omitted provision cannot be kept alive without express preservation, communications founded on the former restriction cannot sustain denial of such refunds.
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