Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
HC held that Section 54(3)(ii) of CGST Act permits refund of Input Tax Credit (ITC) where input and output supplies are identical, rejecting restrictive interpretations in Circular No. 135/05/2020-GST. The court found the respondent's orders erroneously relied on inapplicable circular provisions and improperly rejected refund claims. Consequently, the HC quashed the impugned orders, directing the respondent to refund the accumulated ITC with applicable interest within a specified timeframe, thereby affirming taxpayer's statutory entitlement to ITC refund under the inverted duty structure provisions.
HC held that Section 54(3)(ii) of CGST Act permits refund of Input Tax Credit (ITC) where input and output supplies are identical, rejecting restrictive interpretations in Circular No. 135/05/2020-GST. The court found the respondent's orders erroneously relied on inapplicable circular provisions and improperly rejected refund claims. Consequently, the HC quashed the impugned orders, directing the respondent to refund the accumulated ITC with applicable interest within a specified timeframe, thereby affirming taxpayer's statutory entitlement to ITC refund under the inverted duty structure provisions.
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