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...
The HC directed the respondents to unblock the petitioner's Input Tax Credit (ITC) previously blocked under Rule 86A of the CGST Rules. The Court held that the restriction under Rule 86A(3) ceases upon the petitioner depositing 10% of the disputed tax amount and filing an appeal within the statutory period prescribed under Section 107 of the TNGST Act. Failure to file the appeal within this period would authorize the respondents to re-block the unutilized ITC. Consequently, the petition was disposed of with a mandate to unblock the ITC amounts blocked on specific dates, subject to the petitioner meeting the deposit and appeal conditions.
The HC directed the respondents to unblock the petitioner's Input Tax Credit (ITC) previously blocked under Rule 86A of the CGST Rules. The Court held that the restriction under Rule 86A(3) ceases upon the petitioner depositing 10% of the disputed tax amount and filing an appeal within the statutory period prescribed under Section 107 of the TNGST Act. Failure to file the appeal within this period would authorize the respondents to re-block the unutilized ITC. Consequently, the petition was disposed of with a mandate to unblock the ITC amounts blocked on specific dates, subject to the petitioner meeting the deposit and appeal conditions.
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