Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
HC ruled in favor of petitioner seeking permission to revise GSTR-3B returns for July-November 2017. The case centered on transitional ITC claims under Section 140 of CGST Act 2017. Court acknowledged system limitations, noting TRAN-01 facility was available only from August 25, 2017, despite GST implementation from July 1, 2017. The delay in ITC availability forced petitioner to discharge liability through cash payments. HC emphasized technical glitches shouldn't penalize compliant taxpayers, particularly those under inverted duty structure. The ruling permits revision of returns, allowing proper ITC utilization despite initial system constraints.
HC ruled in favor of petitioner seeking permission to revise GSTR-3B returns for July-November 2017. The case centered on transitional ITC claims under Section 140 of CGST Act 2017. Court acknowledged system limitations, noting TRAN-01 facility was available only from August 25, 2017, despite GST implementation from July 1, 2017. The delay in ITC availability forced petitioner to discharge liability through cash payments. HC emphasized technical glitches shouldn't penalize compliant taxpayers, particularly those under inverted duty structure. The ruling permits revision of returns, allowing proper ITC utilization despite initial system constraints.
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