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...
Input tax credit on reverse charge services from an unregistered foreign supplier was treated as sustainable where the registered recipient raised a self-invoice, discharged tax under reverse charge, and claimed credit on that basis. Reading section 9(3), section 16(2)(a), section 31(3)(f) and rule 36 together, the self-invoice was recognised as a valid tax-paying document, and credit could not be denied merely because the foreign supplier's invoice identified a particular unit. The text also states that, for the relevant period, ITC distribution to other distinct persons without Input Service Distributor registration was not impermissible, as unamended section 20 was only enabling and the later compulsory-registration amendment indicated the earlier position. Revenue neutrality was noted as supporting denial of no technical objection.
Input tax credit on reverse charge services from an unregistered foreign supplier was treated as sustainable where the registered recipient raised a self-invoice, discharged tax under reverse charge, and claimed credit on that basis. Reading section 9(3), section 16(2)(a), section 31(3)(f) and rule 36 together, the self-invoice was recognised as a valid tax-paying document, and credit could not be denied merely because the foreign supplier's invoice identified a particular unit. The text also states that, for the relevant period, ITC distribution to other distinct persons without Input Service Distributor registration was not impermissible, as unamended section 20 was only enabling and the later compulsory-registration amendment indicated the earlier position. Revenue neutrality was noted as supporting denial of no technical objection.
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