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 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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