Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Retrospective amendment to the GST time limit for availing input tax credit preserved ITC entitlement for financial years 2017-18 to 2020-21 where the return under Section 39 had been filed up to 30.11.2021, despite the bar in Section 16(4). The HC, following its earlier common order on the amended provision, quashed the impugned reversal to the extent it denied ITC solely on limitation and protected the taxpayer from recovery on that basis. It left the Department free to proceed separately on other permissible grounds, including wrong, excess or fake ITC, if established independently of limitation.
Retrospective amendment to the GST time limit for availing input tax credit preserved ITC entitlement for financial years 2017-18 to 2020-21 where the return under Section 39 had been filed up to 30.11.2021, despite the bar in Section 16(4). The HC, following its earlier common order on the amended provision, quashed the impugned reversal to the extent it denied ITC solely on limitation and protected the taxpayer from recovery on that basis. It left the Department free to proceed separately on other permissible grounds, including wrong, excess or fake ITC, if established independently of limitation.
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