Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
HC affirmed that blocking under Rule 86A of Orissa GST Rules serves as revenue security by preventing utilization of future ITC through negative balance insertion in electronic credit ledger. The court emphasized the necessity for tax authorities to initiate recovery proceedings within the one-year blocking period, as automatic unblocking would otherwise allow dealers to access and debit ITC from their electronic ledger. The temporary restriction mechanism ensures tax authorities can secure potential recoveries while maintaining procedural safeguards. The ruling clarifies that such preventive measures are valid when aligned with proper recovery actions within the prescribed timeframe.
HC affirmed that blocking under Rule 86A of Orissa GST Rules serves as revenue security by preventing utilization of future ITC through negative balance insertion in electronic credit ledger. The court emphasized the necessity for tax authorities to initiate recovery proceedings within the one-year blocking period, as automatic unblocking would otherwise allow dealers to access and debit ITC from their electronic ledger. The temporary restriction mechanism ensures tax authorities can secure potential recoveries while maintaining procedural safeguards. The ruling clarifies that such preventive measures are valid when aligned with proper recovery actions within the prescribed timeframe.
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