Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The HC dismissed the petitioner's challenge to the respondents' negative blocking of the electronic credit ledger for 01.05.2025-31.05.2025, finding the impugned action authorised under Rule 86A and by a senior officer in the hierarchy despite the petitioner's reliance on the 02.11.2021 circular. The Court held the State Tax Officer had jurisdiction to issue the Form GST DRC-01 show-cause notice and to precipitate ledger blocking. Having noted prior blocking of Rs. 87,86,041, the HC directed respondents to block an additional Rs. 13,00,000 and ordered the petitioner to discharge future tax liabilities 50% in cash and 50% from the electronic credit ledger for one year or until the final order on the DRC-01 notice. Petition disposed.
The HC dismissed the petitioner's challenge to the respondents' negative blocking of the electronic credit ledger for 01.05.2025-31.05.2025, finding the impugned action authorised under Rule 86A and by a senior officer in the hierarchy despite the petitioner's reliance on the 02.11.2021 circular. The Court held the State Tax Officer had jurisdiction to issue the Form GST DRC-01 show-cause notice and to precipitate ledger blocking. Having noted prior blocking of Rs. 87,86,041, the HC directed respondents to block an additional Rs. 13,00,000 and ordered the petitioner to discharge future tax liabilities 50% in cash and 50% from the electronic credit ledger for one year or until the final order on the DRC-01 notice. Petition disposed.
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