Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.
Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.
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