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 ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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GST refund provisions for unutilised input tax credit do not restrict refund applications to suppliers making supplies to SEZ units. The relevant refund rule identifies suppliers as one category of applicants but does not exclude an SEZ unit from claiming its own refund. Reading such a restriction into the statutory scheme would impermissibly add a limiting condition. SEZ units are therefore entitled to have eligible refund claims processed under the GST refund framework, and orders rejecting the claim on that restrictive basis were set aside.
GST refund provisions for unutilised input tax credit do not restrict refund applications to suppliers making supplies to SEZ units. The relevant refund rule identifies suppliers as one category of applicants but does not exclude an SEZ unit from claiming its own refund. Reading such a restriction into the statutory scheme would impermissibly add a limiting condition. SEZ units are therefore entitled to have eligible refund claims processed under the GST refund framework, and orders rejecting the claim on that restrictive basis were set aside.
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