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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GSTR-2A is a facilitation tool rather than a statutory bar to input tax credit. Credit claimed within the extended period for FY 2017-18 requires invoice-wise reconciliation; non-reflection in GSTR-2A for FY 2018-19 alone cannot establish supplier default. Section 75(4) requires a personal hearing before an adverse GST decision, even without a specific request. Return scrutiny under Section 61 and demand proceedings under Section 73 are independent, so absence of FORM GST ASMT-10 does not itself invalidate a direct demand proceeding. Interest and penalty remain consequential to sustainable tax liability. The disputed credit was remanded for verification and fresh adjudication after hearing.
GSTR-2A is a facilitation tool rather than a statutory bar to input tax credit. Credit claimed within the extended period for FY 2017-18 requires invoice-wise reconciliation; non-reflection in GSTR-2A for FY 2018-19 alone cannot establish supplier default. Section 75(4) requires a personal hearing before an adverse GST decision, even without a specific request. Return scrutiny under Section 61 and demand proceedings under Section 73 are independent, so absence of FORM GST ASMT-10 does not itself invalidate a direct demand proceeding. Interest and penalty remain consequential to sustainable tax liability. The disputed credit was remanded for verification and fresh adjudication after hearing.
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