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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Rule 89(4) confines Net ITC for refund of unutilised cess credit on zero-rated supplies to credit actually availed during the relevant refund period. An ITC reversal recorded in GSTR-3B reduces Net ITC only where the reversed credit was availed in that same period; reversals relating to earlier tax periods do not affect the refund computation. Paragraph 43(c) of the departmental circular cannot require deduction of all reversals made during the refund period irrespective of the underlying credit period, as a circular cannot override or expand the statutory refund formula. The accumulated cess-credit refund was consequently sustained.
Rule 89(4) confines Net ITC for refund of unutilised cess credit on zero-rated supplies to credit actually availed during the relevant refund period. An ITC reversal recorded in GSTR-3B reduces Net ITC only where the reversed credit was availed in that same period; reversals relating to earlier tax periods do not affect the refund computation. Paragraph 43(c) of the departmental circular cannot require deduction of all reversals made during the refund period irrespective of the underlying credit period, as a circular cannot override or expand the statutory refund formula. The accumulated cess-credit refund was consequently sustained.
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