Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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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