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...
Recovery of an excess monetary refund of unutilised input tax credit under the inverted-duty scheme may proceed as an erroneous refund under section 73, even where the original refund sanction was not challenged by appeal or revision. The recovery mechanism is distinct from appellate or revisional review of the sanction order. Statutory interest applies under sections 73 and 50 until the principal is repaid; repayment through FORM GST DRC-03 does not close proceedings unless interest is also paid. Substituted Rule 89(5), operative before the refund claim and sanction, governs entitlement; later judicial validation and Rule 88B do not make interest impermissibly retrospective. Interest is computed for the period the erroneous refund remained with the recipient.
Recovery of an excess monetary refund of unutilised input tax credit under the inverted-duty scheme may proceed as an erroneous refund under section 73, even where the original refund sanction was not challenged by appeal or revision. The recovery mechanism is distinct from appellate or revisional review of the sanction order. Statutory interest applies under sections 73 and 50 until the principal is repaid; repayment through FORM GST DRC-03 does not close proceedings unless interest is also paid. Substituted Rule 89(5), operative before the refund claim and sanction, governs entitlement; later judicial validation and Rule 88B do not make interest impermissibly retrospective. Interest is computed for the period the erroneous refund remained with the recipient.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
