Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Reversal of ineligible ITC - The case involved a trader served with a notice to pay/reverse ineligible Input Tax Credit (ITC) due to a discrepancy between GSTR-2A and GSTR-3B filings. The trader argued that they acted in good faith based on invoices from a selling dealer whose GST registration was subsequently cancelled. Legal precedents were cited to challenge the legality of the notice. The High Court determined that the notice was an intimation under Section 74(5), allowing the trader to address the issue before formal proceedings. The Court directed the trader to take necessary actions or file objections, with the adjudicating officer examining objections and relevant documents before initiating formal proceedings.
Reversal of ineligible ITC - The case involved a trader served with a notice to pay/reverse ineligible Input Tax Credit (ITC) due to a discrepancy between GSTR-2A and GSTR-3B filings. The trader argued that they acted in good faith based on invoices from a selling dealer whose GST registration was subsequently cancelled. Legal precedents were cited to challenge the legality of the notice. The High Court determined that the notice was an intimation under Section 74(5), allowing the trader to address the issue before formal proceedings. The Court directed the trader to take necessary actions or file objections, with the adjudicating officer examining objections and relevant documents before initiating formal proceedings.
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