Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Impugned orders set aside, cases remitted to re-examine issue in light of CBIC Circular No.221/15/2024-GST dated 26.06.2024. Petitioner prima facie not liable to pay tax if no invoice raised on NHAI. Tax liability arises when petitioner raises invoice for payment or receives annuities. Mere sub-contracting and advance completion of work for receiving annuity payments over 15 years does not disentitle petitioner from availing input tax credit or infer tax liability on entire contract value without invoicing or payment receipt. Re-examination ordered in light of observations and circular.
Impugned orders set aside, cases remitted to re-examine issue in light of CBIC Circular No.221/15/2024-GST dated 26.06.2024. Petitioner prima facie not liable to pay tax if no invoice raised on NHAI. Tax liability arises when petitioner raises invoice for payment or receives annuities. Mere sub-contracting and advance completion of work for receiving annuity payments over 15 years does not disentitle petitioner from availing input tax credit or infer tax liability on entire contract value without invoicing or payment receipt. Re-examination ordered in light of observations and circular.
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