Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
A High Court held that the six-month time limit for filing a rectification application under Notification No. 22/2024 is procedural and cannot defeat a substantive input tax credit benefit recognised by the retrospective insertion of Sections 16(5) and 16(6). On that basis, rejection of the application as time-barred was not sustained, and the matter was restored for fresh consideration on merits after notice. The respondent was permitted to verify actual entitlement, including whether input tax credit had in fact been availed and whether other statutory conditions were met.
A High Court held that the six-month time limit for filing a rectification application under Notification No. 22/2024 is procedural and cannot defeat a substantive input tax credit benefit recognised by the retrospective insertion of Sections 16(5) and 16(6). On that basis, rejection of the application as time-barred was not sustained, and the matter was restored for fresh consideration on merits after notice. The respondent was permitted to verify actual entitlement, including whether input tax credit had in fact been availed and whether other statutory conditions were met.
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