Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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