SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
