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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Net ITC for refund of unutilised Compensation Cess credit on zero-rated supplies is confined to input tax credit actually availed and attributable to the relevant refund period. A reversal recorded in that period need not reduce Net ITC where records establish that it relates to residual unutilised credit from earlier tax periods and was not included in the credit supporting the refund claim. Paragraph 43(c) of the departmental circular must operate consistently with the statutory refund formula and cannot require deduction of every reversal reported during the period, thereby curtailing a statutory refund entitlement.
Net ITC for refund of unutilised Compensation Cess credit on zero-rated supplies is confined to input tax credit actually availed and attributable to the relevant refund period. A reversal recorded in that period need not reduce Net ITC where records establish that it relates to residual unutilised credit from earlier tax periods and was not included in the credit supporting the refund claim. Paragraph 43(c) of the departmental circular must operate consistently with the statutory refund formula and cannot require deduction of every reversal reported during the period, thereby curtailing a statutory refund entitlement.
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