Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Section 16(5), as inserted retrospectively from 01.07.2017, extends and overrides the time limit under Section 16(4) for claiming input tax credit for financial years 2017 18 to 2020 21, so returns filed within the extended cut off are not barred merely by the earlier time limit; orders denying ITC solely on that time bar were set aside. The matter is remitted to the assessing authority to determine factual eligibility for the claimed ITC, permitting factual reassessment but not re-opening the legal conclusion on the extended time limit.
Section 16(5), as inserted retrospectively from 01.07.2017, extends and overrides the time limit under Section 16(4) for claiming input tax credit for financial years 2017 18 to 2020 21, so returns filed within the extended cut off are not barred merely by the earlier time limit; orders denying ITC solely on that time bar were set aside. The matter is remitted to the assessing authority to determine factual eligibility for the claimed ITC, permitting factual reassessment but not re-opening the legal conclusion on the extended time limit.
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