Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Petitioner challenged denial of input tax credit (ITC) on manpower supply services received during 2017-18 to 2022-23, citing Circular No. 211/5/2024-GST. Court held petitioner entitled to ITC and cannot be deprived or liable for interest due to belated claim, as per circular. Circular supports petitioner's claim, binding on respondents as per KP Varghese judgment. However, as circular issued during pendency, respondent didn't have its benefit earlier. Petition disposed, directing respondent to consider petitioner's objections within three weeks, bearing in mind circular and pass orders accordingly. Petitioner granted liberty to file objections to show cause notice.
Petitioner challenged denial of input tax credit (ITC) on manpower supply services received during 2017-18 to 2022-23, citing Circular No. 211/5/2024-GST. Court held petitioner entitled to ITC and cannot be deprived or liable for interest due to belated claim, as per circular. Circular supports petitioner's claim, binding on respondents as per KP Varghese judgment. However, as circular issued during pendency, respondent didn't have its benefit earlier. Petition disposed, directing respondent to consider petitioner's objections within three weeks, bearing in mind circular and pass orders accordingly. Petitioner granted liberty to file objections to show cause notice.
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