Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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CESTAT allowed appellant's appeal, holding that transitional service tax credit of Rs. 6,15,409/- is admissible despite procedural error in form TRAN-1. The tribunal determined that technical glitch in entering data at incorrect serial number does not vitiate substantive rights. Revenue directed to treat data entered at Sr. No. 5 as equivalent to entry at Sr. No. 11, recognizing that procedural infirmities cannot defeat legitimate tax credit entitlement under Section 142(11)(c) and Rule 118 of CGST Rules, 2017. The core principle affirmed is that substantial rights supersede minor procedural non-compliance in tax credit transition.
CESTAT allowed appellant's appeal, holding that transitional service tax credit of Rs. 6,15,409/- is admissible despite procedural error in form TRAN-1. The tribunal determined that technical glitch in entering data at incorrect serial number does not vitiate substantive rights. Revenue directed to treat data entered at Sr. No. 5 as equivalent to entry at Sr. No. 11, recognizing that procedural infirmities cannot defeat legitimate tax credit entitlement under Section 142(11)(c) and Rule 118 of CGST Rules, 2017. The core principle affirmed is that substantial rights supersede minor procedural non-compliance in tax credit transition.
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