Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
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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