Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
HC allowed the petition concerning irregularly availed Input Tax Credit (ITC), finding that Circular dated 15.10.2024 retrospectively extended the time limit for ITC under Section 16(4) of CGST Act, 2017. The Deputy Solicitor General conceded that petitioner is now entitled to the previously denied ITC based on the new notification and circular provisions. The court's ruling effectively reinstates the petitioner's right to claim input tax credit beyond the original statutory cut-off dates, providing retrospective relief for tax credit claims.
HC allowed the petition concerning irregularly availed Input Tax Credit (ITC), finding that Circular dated 15.10.2024 retrospectively extended the time limit for ITC under Section 16(4) of CGST Act, 2017. The Deputy Solicitor General conceded that petitioner is now entitled to the previously denied ITC based on the new notification and circular provisions. The court's ruling effectively reinstates the petitioner's right to claim input tax credit beyond the original statutory cut-off dates, providing retrospective relief for tax credit claims.
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