Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Rule 86A(3) of the CGST Rules, 2017 limits blocking of an electronic credit ledger to one year from the date of imposition, so the restriction ceased by operation of law once that period expired. The HC held that the petitioner was entitled to unblocking without a separate declaration, and rejected the Department's reliance on cancellation of registration or possible future proceedings to extend an expired restriction. The impugned blocking was set aside, while issues concerning ITC eligibility and any other proceedings were expressly left open.
Rule 86A(3) of the CGST Rules, 2017 limits blocking of an electronic credit ledger to one year from the date of imposition, so the restriction ceased by operation of law once that period expired. The HC held that the petitioner was entitled to unblocking without a separate declaration, and rejected the Department's reliance on cancellation of registration or possible future proceedings to extend an expired restriction. The impugned blocking was set aside, while issues concerning ITC eligibility and any other proceedings were expressly left open.
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