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 Rule 86-A of the CGST Rules cannot be construed to effectuate "negative blocking" of Input Tax Credit by precluding credits that were not present in the petitioner's Electronic Credit Ledger on the date the satisfaction and blocking order were recorded. Applying a literal construction of the taxing statute, the court found no ambiguity permitting the blocking of prospective or subsequently accruing ITC and concluded such an interpretation would exceed the rule-making power and contradict the rule framers' intent. The impugned blocking notice was quashed and set aside; the petition succeeded and the application was disposed of.
The HC held that Rule 86-A of the CGST Rules cannot be construed to effectuate "negative blocking" of Input Tax Credit by precluding credits that were not present in the petitioner's Electronic Credit Ledger on the date the satisfaction and blocking order were recorded. Applying a literal construction of the taxing statute, the court found no ambiguity permitting the blocking of prospective or subsequently accruing ITC and concluded such an interpretation would exceed the rule-making power and contradict the rule framers' intent. The impugned blocking notice was quashed and set aside; the petition succeeded and the application was disposed of.
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