Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Section 148 permits the Government, on the Council's recommendations and subject to conditions and safeguards, to notify classes of registered persons and special procedures for registration, returns, tax payment and administration. Notification No. 22/2024-Central Tax, prescribing a procedure to implement retrospective input tax credit entitlement under Section 16(5), therefore falls within that power. The validity of the stipulated six-month period for rectification, particularly whether it contains adequate safeguards despite no extension mechanism for extraordinary circumstances, remains under consideration. The writ petitions were kept pending on that limited issue.
Section 148 permits the Government, on the Council's recommendations and subject to conditions and safeguards, to notify classes of registered persons and special procedures for registration, returns, tax payment and administration. Notification No. 22/2024-Central Tax, prescribing a procedure to implement retrospective input tax credit entitlement under Section 16(5), therefore falls within that power. The validity of the stipulated six-month period for rectification, particularly whether it contains adequate safeguards despite no extension mechanism for extraordinary circumstances, remains under consideration. The writ petitions were kept pending on that limited issue.
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