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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
