Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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HC examined the petitioner's challenge to blocking of its Electronic Credit Ledger (ECL) under Rule 86A of the CGST Rules. Endorsing views of other HCs, it held that Rule 86A permits only temporary restriction on debit of legitimately available ITC where there is "reason to believe" of fraudulent or ineligible credit, without requiring prior show cause notice, as it addresses emergent situations. However, the HC ruled that "negative blocking" beyond the actual ITC balance is impermissible. Following its earlier decision, the HC set aside the impugned entries/orders to the extent they disallowed debit in excess of available ITC and allowed the writ petition.
HC examined the petitioner's challenge to blocking of its Electronic Credit Ledger (ECL) under Rule 86A of the CGST Rules. Endorsing views of other HCs, it held that Rule 86A permits only temporary restriction on debit of legitimately available ITC where there is "reason to believe" of fraudulent or ineligible credit, without requiring prior show cause notice, as it addresses emergent situations. However, the HC ruled that "negative blocking" beyond the actual ITC balance is impermissible. Following its earlier decision, the HC set aside the impugned entries/orders to the extent they disallowed debit in excess of available ITC and allowed the writ petition.
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