Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
HC held that the electronic credit ledger constitutes a unified resource with interconnected tax compartments (IGST, CGST, SGST). The court found that erroneously claiming Input Tax Credit under different heads does not automatically invalidate the claim. The impugned orders were set aside, directing the tax authority to reconsider the ITC claim afresh within three months. The decision emphasizes a holistic approach to interpreting tax credit utilization, treating the electronic credit ledger as an integrated fund pool rather than strictly segregated compartments. Petition allowed with remand.
HC held that the electronic credit ledger constitutes a unified resource with interconnected tax compartments (IGST, CGST, SGST). The court found that erroneously claiming Input Tax Credit under different heads does not automatically invalidate the claim. The impugned orders were set aside, directing the tax authority to reconsider the ITC claim afresh within three months. The decision emphasizes a holistic approach to interpreting tax credit utilization, treating the electronic credit ledger as an integrated fund pool rather than strictly segregated compartments. Petition allowed with remand.
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