Condonation of Delay: Tribunal directed condonation where rectification proceedings were pursued, ordering merits adjudication after opportunity to be...
Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Tribunal held that clause (i) of the statutory provision defining specified domestic transactions was omitted with retrospective effect, applying established precedent on retrospective omission so the provision is treated as never having existed; consequently references to the Transfer Pricing Officer and transfer pricing adjustments for the relevant assessment year were invalid and the additions based solely on that provision were directed to be deleted, leading to allowance of the appeal and removal of the contested additions.
Tribunal held that clause (i) of the statutory provision defining specified domestic transactions was omitted with retrospective effect, applying established precedent on retrospective omission so the provision is treated as never having existed; consequently references to the Transfer Pricing Officer and transfer pricing adjustments for the relevant assessment year were invalid and the additions based solely on that provision were directed to be deleted, leading to allowance of the appeal and removal of the contested additions.
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