Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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