Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
HC upheld denial of input tax credit (ITC) under GST law. Petitioners failed to demonstrate actual receipt of goods and legitimacy of transactions with suppliers. Court emphasized that while Section 7's definition of supply is broad, valid ITC claims must satisfy Section 16(2)(b) requirements. Despite petitioners' argument regarding denied cross-examination of suppliers, HC ruled this wasn't a violation of natural justice. Key findings centered on petitioners' failure to maintain proper documentation, including e-way bills for goods valued over Rs.50,000, and inability to prove physical receipt of goods. Per Rule 36 and Section 16(2), burden of proving valid receipt lies with recipient. Without meeting these statutory requirements, provisional credit must be reversed. Petition dismissed.
HC upheld denial of input tax credit (ITC) under GST law. Petitioners failed to demonstrate actual receipt of goods and legitimacy of transactions with suppliers. Court emphasized that while Section 7's definition of supply is broad, valid ITC claims must satisfy Section 16(2)(b) requirements. Despite petitioners' argument regarding denied cross-examination of suppliers, HC ruled this wasn't a violation of natural justice. Key findings centered on petitioners' failure to maintain proper documentation, including e-way bills for goods valued over Rs.50,000, and inability to prove physical receipt of goods. Per Rule 36 and Section 16(2), burden of proving valid receipt lies with recipient. Without meeting these statutory requirements, provisional credit must be reversed. Petition dismissed.
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