Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.
Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.
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