Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Unutilised input tax credit accumulated from an inverted duty structure is refundable where manufacturing inputs are taxed at a higher rate than the outward supply and are distinct from the finished goods. For Agarbati manufacturing, perfumes, fragrances, chemicals, packaging materials and cardboard qualify as inputs whose higher tax rates may support refund eligibility. A CBIC clarification addressing situations where input and output supplies are the same goods does not restrict such claims. CBIC circulars bind central tax officers but not the Appellate Tribunal, although they may carry persuasive value.
Unutilised input tax credit accumulated from an inverted duty structure is refundable where manufacturing inputs are taxed at a higher rate than the outward supply and are distinct from the finished goods. For Agarbati manufacturing, perfumes, fragrances, chemicals, packaging materials and cardboard qualify as inputs whose higher tax rates may support refund eligibility. A CBIC clarification addressing situations where input and output supplies are the same goods does not restrict such claims. CBIC circulars bind central tax officers but not the Appellate Tribunal, although they may carry persuasive value.
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