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...
Inadmissible ITC utilization from cancelled suppliers - petitioner disclosed inward tax supply invoices, party ledger, bank statements, GSTR-2A and e-waybills for supplies allegedly made by a supplier during September-October 2017. Although petitioner discharged initial burden of proof, appellate authority found petitioner ineligible for ITC without specifying documents required to establish transaction genuineness. Appellate authority's order suffered from non-application of mind, being verbatim reproduction of adjudicating authority's observations. Matter remanded to appellate authority to reconsider issue of movement of goods and indicate documents petitioner required to disclose for establishing transaction genuineness. Petition allowed by way of remand.
Inadmissible ITC utilization from cancelled suppliers - petitioner disclosed inward tax supply invoices, party ledger, bank statements, GSTR-2A and e-waybills for supplies allegedly made by a supplier during September-October 2017. Although petitioner discharged initial burden of proof, appellate authority found petitioner ineligible for ITC without specifying documents required to establish transaction genuineness. Appellate authority's order suffered from non-application of mind, being verbatim reproduction of adjudicating authority's observations. Matter remanded to appellate authority to reconsider issue of movement of goods and indicate documents petitioner required to disclose for establishing transaction genuineness. Petition allowed by way of remand.
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