Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The HC held that Input Tax Credit (ITC) claims must typically be made in the Return or Revised Return, with exceptions requiring demonstrated bona fides. Rectification of underclaimed ITC due to bona fide mistakes in tax rates is permissible through representation when foundational facts are available in the Return/Revised Return. No rectification is permitted after assessment/reassessment proceedings conclude or limitation period expires. During reassessment, ITC claims cannot be disallowed merely because they disadvantage the State Exchequer. If reassessed tax exceeds payable amount, recovery with interest/penalty is warranted; conversely, if payment exceeds reassessed liability, ITC claims made before conclusion of reassessment proceedings must be honored. Petition dismissed.
The HC held that Input Tax Credit (ITC) claims must typically be made in the Return or Revised Return, with exceptions requiring demonstrated bona fides. Rectification of underclaimed ITC due to bona fide mistakes in tax rates is permissible through representation when foundational facts are available in the Return/Revised Return. No rectification is permitted after assessment/reassessment proceedings conclude or limitation period expires. During reassessment, ITC claims cannot be disallowed merely because they disadvantage the State Exchequer. If reassessed tax exceeds payable amount, recovery with interest/penalty is warranted; conversely, if payment exceeds reassessed liability, ITC claims made before conclusion of reassessment proceedings must be honored. Petition dismissed.
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