Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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HC held that under s.50, interest on GST accrues only until the liability crystallises on filing of the return in Form GSTR-3B or upon debit in the electronic cash ledger; however, where an assessee had deposited tax and interest which was immediately credited to the Government account and subsequently debited from the electronic cash ledger on filing the return, the tax liability stood discharged as of the deposit date and no interest could be levied from the date of deposit until filing of the return/DRC-03. The petition of the assessee was allowed and the respondents' claim for interest accruing after deposit was rejected.
HC held that under s.50, interest on GST accrues only until the liability crystallises on filing of the return in Form GSTR-3B or upon debit in the electronic cash ledger; however, where an assessee had deposited tax and interest which was immediately credited to the Government account and subsequently debited from the electronic cash ledger on filing the return, the tax liability stood discharged as of the deposit date and no interest could be levied from the date of deposit until filing of the return/DRC-03. The petition of the assessee was allowed and the respondents' claim for interest accruing after deposit was rejected.
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