Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Input tax credit under section 16(5) of the CGST Act is a retrospective statutory entitlement where relevant returns were filed within the prescribed cut-off. Failure to submit a rectification application within the period set by a departmental circular does not by itself defeat that entitlement. The denial of credit was quashed because the show-cause notice acknowledged timely filing under section 16(5), and the claim was remitted for reconsideration, subject to satisfaction of other eligibility conditions.
Input tax credit under section 16(5) of the CGST Act is a retrospective statutory entitlement where relevant returns were filed within the prescribed cut-off. Failure to submit a rectification application within the period set by a departmental circular does not by itself defeat that entitlement. The denial of credit was quashed because the show-cause notice acknowledged timely filing under section 16(5), and the claim was remitted for reconsideration, subject to satisfaction of other eligibility conditions.
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