Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The court held that the issue in controversy regarding the legality of sub-section (4) to Section 16 of the Central Goods and Service Tax Act, 2017 and the Karnataka Goods and Service Tax Act, 2017, concerning the date of availment of input tax credit (ITC) in the books of account of the petitioner, is directly and squarely covered by its previous judgment in M/s. Sadhana Enviro Engineering Services vs. Joint Commissioner of Central Tax & Others. In that case, the court directed the respondents to unblock and release the credit balance of the petitioner in their ITC Ledger/Account immediately and without delay. Consequently, the present petition deserves to be allowed and disposed of accordingly.
The court held that the issue in controversy regarding the legality of sub-section (4) to Section 16 of the Central Goods and Service Tax Act, 2017 and the Karnataka Goods and Service Tax Act, 2017, concerning the date of availment of input tax credit (ITC) in the books of account of the petitioner, is directly and squarely covered by its previous judgment in M/s. Sadhana Enviro Engineering Services vs. Joint Commissioner of Central Tax & Others. In that case, the court directed the respondents to unblock and release the credit balance of the petitioner in their ITC Ledger/Account immediately and without delay. Consequently, the present petition deserves to be allowed and disposed of accordingly.
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