Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Dispute centered on Rule 21(8) of Punjab VAT Rules regarding input tax credit (ITC) calculations following tax rate reduction on iron and steel goods. SC upheld HC's ruling that Rule 21(8), introduced from 01.02.2014, could not be applied retroactively to reduce ITC on existing stock purchased at higher tax rates before the enabling provision in Punjab VAT Act came into effect on 01.04.2014. Following Eicher Motors precedent, SC affirmed that right to ITC accrues when tax is paid on inputs and cannot be diminished retroactively. Court emphasized that allowing retroactive application would cause prejudice to taxpayers who had legitimately claimed ITC at higher rates and could lead to revenue loss. Appeal dismissed, confirming that Rule 21(8) applies only to transactions from 01.04.2014 onwards.
Dispute centered on Rule 21(8) of Punjab VAT Rules regarding input tax credit (ITC) calculations following tax rate reduction on iron and steel goods. SC upheld HC's ruling that Rule 21(8), introduced from 01.02.2014, could not be applied retroactively to reduce ITC on existing stock purchased at higher tax rates before the enabling provision in Punjab VAT Act came into effect on 01.04.2014. Following Eicher Motors precedent, SC affirmed that right to ITC accrues when tax is paid on inputs and cannot be diminished retroactively. Court emphasized that allowing retroactive application would cause prejudice to taxpayers who had legitimately claimed ITC at higher rates and could lead to revenue loss. Appeal dismissed, confirming that Rule 21(8) applies only to transactions from 01.04.2014 onwards.
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