Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Refund of accumulated input tax credit under an inverted duty structure remains available where processed fabrics retain the same GST rate and credit accumulates from higher-taxed chemicals, dyes and consumables used in job-work processing. Circular No. 135/05/2020-GST concerns credit accumulation caused by a GST-rate reduction on the same goods and does not bar such refund claims. Once substantive refund eligibility is determined, an appellate direction for arithmetical recomputation merely implements that determination and is not a prohibited remand, provided the original authority cannot reconsider the merits. Refund orders allowing consequential recalculation were sustained.
Refund of accumulated input tax credit under an inverted duty structure remains available where processed fabrics retain the same GST rate and credit accumulates from higher-taxed chemicals, dyes and consumables used in job-work processing. Circular No. 135/05/2020-GST concerns credit accumulation caused by a GST-rate reduction on the same goods and does not bar such refund claims. Once substantive refund eligibility is determined, an appellate direction for arithmetical recomputation merely implements that determination and is not a prohibited remand, provided the original authority cannot reconsider the merits. Refund orders allowing consequential recalculation were sustained.
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