Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
ITAT upheld characterization of outstanding dues beyond agreed credit period as separate international transaction of providing finance, requiring separate benchmarking. Interest adjustment limited to financial year under consideration. RBI COVID-19 relaxations not applicable to relevant period. No recharacterization of transaction by TPO. Commercial expediency for delayed receivables not established. Netting of receivables/payables permitted if demonstrated. Lack of show cause notice not fatal. Working capital adjustment to be considered for removing interest adjustment. MAT book profit computation remitted for rectification. Directed to grant tax credits after verification.
ITAT upheld characterization of outstanding dues beyond agreed credit period as separate international transaction of providing finance, requiring separate benchmarking. Interest adjustment limited to financial year under consideration. RBI COVID-19 relaxations not applicable to relevant period. No recharacterization of transaction by TPO. Commercial expediency for delayed receivables not established. Netting of receivables/payables permitted if demonstrated. Lack of show cause notice not fatal. Working capital adjustment to be considered for removing interest adjustment. MAT book profit computation remitted for rectification. Directed to grant tax credits after verification.
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