Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
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...
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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.
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