Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
HC ruled that blocking of Input Tax Credit (ITC) ledger beyond one year under Rule 86A of CGST Rules, 2017, must be lifted. The statutory interpretation of Rule 86A(3) mandates automatic removal of credit restrictions after the specified time period. The court's decision explicitly notes that lifting the ITC block is independent of any concurrent administrative or legal proceedings against the taxpayer. The restriction is therefore automatically terminated after the one-year period, providing relief to the petitioner while preserving the authority's right to pursue separate investigative actions.
HC ruled that blocking of Input Tax Credit (ITC) ledger beyond one year under Rule 86A of CGST Rules, 2017, must be lifted. The statutory interpretation of Rule 86A(3) mandates automatic removal of credit restrictions after the specified time period. The court's decision explicitly notes that lifting the ITC block is independent of any concurrent administrative or legal proceedings against the taxpayer. The restriction is therefore automatically terminated after the one-year period, providing relief to the petitioner while preserving the authority's right to pursue separate investigative actions.
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