Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
The HC held that validly availed input tax credit (ITC) is indefeasible unless utilized improperly. The imposition of interest u/s 50(3) requires actual utilization of the credit. Since the petitioner had not utilized the accumulated ITC after the cut-off date, the imposition of interest as per the impugned circular could not be justified. The petition was allowed.
The HC held that validly availed input tax credit (ITC) is indefeasible unless utilized improperly. The imposition of interest u/s 50(3) requires actual utilization of the credit. Since the petitioner had not utilized the accumulated ITC after the cut-off date, the imposition of interest as per the impugned circular could not be justified. The petition was allowed.
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