SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
HC held that respondents' recovery of amount from petitioner's Electronic Credit Ledger/Electronic Cash Ledger under Section 79 of GST Act, 2017 was illegal and arbitrary. Court found that pursuant to Section 78, recovery proceedings cannot be initiated within three months of demand becoming payable unless reasons are recorded. Additionally, under Section 112(9), deposit of 10% of demand stays remaining amount, with three-month limitation for appeal filing. CBIC circular dated 11.07.2024 permits pre-deposit even when appellate tribunals are not constituted. Since respondents recovered amount on 29.01.2025 without complying with statutory requirements, HC quashed and set aside the recovery action. Petition allowed.
HC held that respondents' recovery of amount from petitioner's Electronic Credit Ledger/Electronic Cash Ledger under Section 79 of GST Act, 2017 was illegal and arbitrary. Court found that pursuant to Section 78, recovery proceedings cannot be initiated within three months of demand becoming payable unless reasons are recorded. Additionally, under Section 112(9), deposit of 10% of demand stays remaining amount, with three-month limitation for appeal filing. CBIC circular dated 11.07.2024 permits pre-deposit even when appellate tribunals are not constituted. Since respondents recovered amount on 29.01.2025 without complying with statutory requirements, HC quashed and set aside the recovery action. Petition allowed.
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TaxTMI 
TaxTMI 
of 4879 
