Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The High Court held that the petitioners were entitled to refund of unutilized input tax credit (ITC) on zero-rated supplies. The only ground for denying refund by the appellate authority was that no balance was available in the electronic credit ledger when the petitioners became entitled to the refund, as the carried forward CENVAT credit from the earlier regime was approved later. This would be contrary to Section 140(1) of the CGST Act. Consequently, the orders denying refund were quashed, and the appeal was allowed.
The High Court held that the petitioners were entitled to refund of unutilized input tax credit (ITC) on zero-rated supplies. The only ground for denying refund by the appellate authority was that no balance was available in the electronic credit ledger when the petitioners became entitled to the refund, as the carried forward CENVAT credit from the earlier regime was approved later. This would be contrary to Section 140(1) of the CGST Act. Consequently, the orders denying refund were quashed, and the appeal was allowed.
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