Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
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Rule 86A permits restriction on debit of input tax credit in an electronic credit ledger only when its prescribed conditions are met, including recorded reasons to believe and reasons in writing. The High Court found that the authorities could not establish compliance with these mandatory requirements before blocking the ledger. As the statutory period had expired and the ledger had been reactivated, the writ petition was disposed of exceptionally upon acceptance of an unconditional apology. The High Court warned that any future non-compliant blocking of credit would expose the authorities to appropriate compensation liability.
Rule 86A permits restriction on debit of input tax credit in an electronic credit ledger only when its prescribed conditions are met, including recorded reasons to believe and reasons in writing. The High Court found that the authorities could not establish compliance with these mandatory requirements before blocking the ledger. As the statutory period had expired and the ledger had been reactivated, the writ petition was disposed of exceptionally upon acceptance of an unconditional apology. The High Court warned that any future non-compliant blocking of credit would expose the authorities to appropriate compensation liability.
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