Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The AAAR dismissed the appeal and held that import IGST paid via TR-6 challan is not an admissible document for claiming ITC because a TR-6 is a Treasury payment instrument and not a "bill of entry or any similar document" prescribed under the Customs Act or rules; consequently TR-6 (alone or read with SVB orders/letters) cannot support ITC. A re-assessed bill of entry, however, constitutes a prescribed document under r.36(1)(d) and thus may permit ITC, but such availment is governed by the time-bar in s.16(4) CGST, applied to IGST claims by s.20 IGST Act mutatis mutandis. Appeal dismissed.
The AAAR dismissed the appeal and held that import IGST paid via TR-6 challan is not an admissible document for claiming ITC because a TR-6 is a Treasury payment instrument and not a "bill of entry or any similar document" prescribed under the Customs Act or rules; consequently TR-6 (alone or read with SVB orders/letters) cannot support ITC. A re-assessed bill of entry, however, constitutes a prescribed document under r.36(1)(d) and thus may permit ITC, but such availment is governed by the time-bar in s.16(4) CGST, applied to IGST claims by s.20 IGST Act mutatis mutandis. Appeal dismissed.
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