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 taxpayer's refund application for unutilized Input Tax Credit (ITC) filed on 07.11.2022 for periods prior to 18.07.2022 is maintainable, as it was within the statutory limitation period under Section 54(1). Following the precedent in Patanjali Foods case, the court quashed the department's rejection order, which improperly relied on Circular No.181/13/2022-GST. The refund claim was deemed valid, rejecting the administrative circular's attempt to create arbitrary classification of refund applications, thereby ensuring taxpayer's legal right to claim refund within prescribed timelines.
HC held that the taxpayer's refund application for unutilized Input Tax Credit (ITC) filed on 07.11.2022 for periods prior to 18.07.2022 is maintainable, as it was within the statutory limitation period under Section 54(1). Following the precedent in Patanjali Foods case, the court quashed the department's rejection order, which improperly relied on Circular No.181/13/2022-GST. The refund claim was deemed valid, rejecting the administrative circular's attempt to create arbitrary classification of refund applications, thereby ensuring taxpayer's legal right to claim refund within prescribed timelines.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
