Transitional input tax credit subject to statutory time and manner; cut-off rules enforceable despite portal glitches.
Transitional input tax credit is a statutory, non vested benefit claimable only in the time and manner prescribed by Section 140 and rules; Rule 117 and Rule 120A are within rule making powers, prescribe rational mandatory cut off dates for filing TRAN 1/TRAN 2, and administrative measures limiting credit to eligible duties and setting procedural safeguards align with the statutory scheme. Portal failures do not automatically excuse non filing where the framework operated for the majority of taxpayers. (AI Summary)
Transitional input tax credit is a statutory, non vested benefit claimable only in the time and manner prescribed by Section 140 and rules; Rule 117 and Rule 120A are within rule making powers, prescribe rational mandatory cut off dates for filing TRAN 1/TRAN 2, and administrative measures limiting credit to eligible duties and setting procedural safeguards align with the statutory scheme. Portal failures do not automatically excuse non filing where the framework operated for the majority of taxpayers. (AI Summary)
TaxTMI