Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
Input tax credit denial based solely on a GSTR-2A/GSTR-3B mismatch requires transaction-level verification of reconciliations, invoices, records and supplier-tax-payment conditions; a mismatch alone does not establish ineligibility. Section 16(2)(aa) does not apply to the disputed period, while Rule 36(4) must be applied as operative during each relevant portion. Tax demands must remain within the grounds and tax heads proposed in the show-cause notice, supported by a reasoned computation and factual basis. The CBIC ITC-verification mechanism applies only from April 2019 to 8 October 2019, requiring separate examination of later periods under the applicable substantive provisions.
Input tax credit denial based solely on a GSTR-2A/GSTR-3B mismatch requires transaction-level verification of reconciliations, invoices, records and supplier-tax-payment conditions; a mismatch alone does not establish ineligibility. Section 16(2)(aa) does not apply to the disputed period, while Rule 36(4) must be applied as operative during each relevant portion. Tax demands must remain within the grounds and tax heads proposed in the show-cause notice, supported by a reasoned computation and factual basis. The CBIC ITC-verification mechanism applies only from April 2019 to 8 October 2019, requiring separate examination of later periods under the applicable substantive provisions.
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