Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Rejection of the transition of the ITC - Levy of penalty for wrongful transition, ineligible credit as well as interest - rejection of transition of ITC - The motives of the petitioner are found to be bondfide in law, since it not only asks for a refund but also states that it is not entitled for transition under GST laws. - Let the refund claim dated 19.07.2017 be processed on merits by the State Taxes Officer/R1, and paid over to the petitioner with interest till 27.12.2017, being the date when the TRAN 1 application was filed by the petitioner, within a period of four weeks from date of receipt of copy of this order. - HC
Rejection of the transition of the ITC - Levy of penalty for wrongful transition, ineligible credit as well as interest - rejection of transition of ITC - The motives of the petitioner are found to be bondfide in law, since it not only asks for a refund but also states that it is not entitled for transition under GST laws. - Let the refund claim dated 19.07.2017 be processed on merits by the State Taxes Officer/R1, and paid over to the petitioner with interest till 27.12.2017, being the date when the TRAN 1 application was filed by the petitioner, within a period of four weeks from date of receipt of copy of this order. - HC
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