Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The court held that Rule 86A empowers the Commissioner or authorized officer to restrict debit of fraudulently availed or ineligible Input Tax Credit (ITC) from the electronic credit ledger for discharge of liabilities or refund claims, subject to recording reasons in writing. Sub-rule (3) mandates that such restriction shall cease after one year from imposition. As the restriction was imposed on 23rd November 2022 and one year lapsed around 23rd November 2023, the restriction has ceased by operation of law. The petition was disposed of accordingly.
The court held that Rule 86A empowers the Commissioner or authorized officer to restrict debit of fraudulently availed or ineligible Input Tax Credit (ITC) from the electronic credit ledger for discharge of liabilities or refund claims, subject to recording reasons in writing. Sub-rule (3) mandates that such restriction shall cease after one year from imposition. As the restriction was imposed on 23rd November 2022 and one year lapsed around 23rd November 2023, the restriction has ceased by operation of law. The petition was disposed of accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
