Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Section 16(5) of the CGST Act, inserted retrospectively, grants input tax credit to taxpayers who furnished returns by its prescribed cut-off date, notwithstanding the time limit in Section 16(4). A circular cannot restrict that statutory entitlement. A notification requiring a rectification application within a specified period does not govern a taxpayer who had already filed an appeal against the assessment order before the amendment. Denial of March 2020 input tax credit and consequential demands therefore require reconsideration under Section 16(5), subject to other eligibility conditions.
Section 16(5) of the CGST Act, inserted retrospectively, grants input tax credit to taxpayers who furnished returns by its prescribed cut-off date, notwithstanding the time limit in Section 16(4). A circular cannot restrict that statutory entitlement. A notification requiring a rectification application within a specified period does not govern a taxpayer who had already filed an appeal against the assessment order before the amendment. Denial of March 2020 input tax credit and consequential demands therefore require reconsideration under Section 16(5), subject to other eligibility conditions.
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