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...
Net ITC for refunds of unutilised compensation cess on zero-rated supplies comprises credit actually availed and attributable to the relevant refund period. A reversal recorded in that period reduces Net ITC only where the reversed credit was availed during the same period. Residual credit from earlier periods, not included in the claimed Net ITC for the refund period, cannot reduce the eligible refund. Departmental clarification must operate consistently with the statutory refund formula and cannot require deduction of every reversal irrespective of when the underlying credit arose. The refund sanction was therefore upheld and the Revenue challenge rejected.
Net ITC for refunds of unutilised compensation cess on zero-rated supplies comprises credit actually availed and attributable to the relevant refund period. A reversal recorded in that period reduces Net ITC only where the reversed credit was availed during the same period. Residual credit from earlier periods, not included in the claimed Net ITC for the refund period, cannot reduce the eligible refund. Departmental clarification must operate consistently with the statutory refund formula and cannot require deduction of every reversal irrespective of when the underlying credit arose. The refund sanction was therefore upheld and the Revenue challenge rejected.
Note: It is a system-generated summary and is for quick reference only.