Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rule 86A does not permit negative blocking of input tax credit in the electronic credit ledger by restricting credits that may arise in the future. The High Court notes that, following Rawman Metal & Alloys and subsequent consistent decisions, blocking may not exceed credit available in the ledger even where wrongful or fraudulent availment from non-genuine or non-existent suppliers is alleged. Orders producing negative blocking were quashed, while preserving the respondent's ability to take further action permitted by law, including restoring blocked credit where legally permissible.
Rule 86A does not permit negative blocking of input tax credit in the electronic credit ledger by restricting credits that may arise in the future. The High Court notes that, following Rawman Metal & Alloys and subsequent consistent decisions, blocking may not exceed credit available in the ledger even where wrongful or fraudulent availment from non-genuine or non-existent suppliers is alleged. Orders producing negative blocking were quashed, while preserving the respondent's ability to take further action permitted by law, including restoring blocked credit where legally permissible.
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