Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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