Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
The HC held that the powers under Rule 86A of the CGST Rules may be exercised only in respect of input tax credit reflected in the Electronic Credit Ledger on the date of making and serving the impugned blocking order. Applying precedent, the court quashed and set aside the impugned order insofar as it exceeded that scope and directed the Respondents to restore to the Petitioner the blocked input tax credit equivalent to amounts recovered by the Respondents for June, July and August 2025 that are not otherwise set aside. The directive mandates restoration of ledger credit while preserving any recoveries that remain valid.
The HC held that the powers under Rule 86A of the CGST Rules may be exercised only in respect of input tax credit reflected in the Electronic Credit Ledger on the date of making and serving the impugned blocking order. Applying precedent, the court quashed and set aside the impugned order insofar as it exceeded that scope and directed the Respondents to restore to the Petitioner the blocked input tax credit equivalent to amounts recovered by the Respondents for June, July and August 2025 that are not otherwise set aside. The directive mandates restoration of ledger credit while preserving any recoveries that remain valid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
