Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Issue: Whether blocking electronic input tax credit under Rule 86A was predicated on an independent, reasoned satisfaction or on a mechanical/borrowed conclusion. Reasoning: The court held that Rule 86A requires an independent application of mind and a speaking order; reliance on the Board's Circular dated 02.11.2021 does not permit a mere mechanical exercise or borrowed satisfaction. Outcome: The tax authority was directed to pass a fresh reasoned speaking order complying with Rule 86A, and the writ was disposed. - HC
Issue: Whether blocking electronic input tax credit under Rule 86A was predicated on an independent, reasoned satisfaction or on a mechanical/borrowed conclusion. Reasoning: The court held that Rule 86A requires an independent application of mind and a speaking order; reliance on the Board's Circular dated 02.11.2021 does not permit a mere mechanical exercise or borrowed satisfaction. Outcome: The tax authority was directed to pass a fresh reasoned speaking order complying with Rule 86A, and the writ was disposed. - HC
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