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 held that the retrospective extension of the time limit to avail input tax credit under sub-section (4) of Section 16 of the CGST Act, as per the Ministry of Finance circular dated 15-10-2024, permits taxpayers to seek rectification of orders passed under Sections 73, 74, 107, or 108 of the CGST Act regarding wrongful input tax credit claims. Pursuant to the special procedure under Section 148, notified on 8-10-2024, rectification applications may be filed within six months from 15-10-2024, i.e., until 15-4-2025. The petitioner was granted leave to file such an application, and the petition was accordingly disposed of.
The HC held that the retrospective extension of the time limit to avail input tax credit under sub-section (4) of Section 16 of the CGST Act, as per the Ministry of Finance circular dated 15-10-2024, permits taxpayers to seek rectification of orders passed under Sections 73, 74, 107, or 108 of the CGST Act regarding wrongful input tax credit claims. Pursuant to the special procedure under Section 148, notified on 8-10-2024, rectification applications may be filed within six months from 15-10-2024, i.e., until 15-4-2025. The petitioner was granted leave to file such an application, and the petition was accordingly disposed of.
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