Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The HC held that Notification No. 14/2022-Central Tax amending Rule 89(5) of the CGST Rules had to be applied even to refund applications filed before 5 July 2022, following the final view in Ascent Meditech Ltd. The appellate authority's failure to consider that notification and the related clarification rendered its rejection of the refund claims unsustainable. On a composite reading of Section 54(3) and the Rules, the petitioner was entitled to refund of accumulated input tax credit arising from the inverted duty structure, and the original and appellate rejection orders were quashed.
The HC held that Notification No. 14/2022-Central Tax amending Rule 89(5) of the CGST Rules had to be applied even to refund applications filed before 5 July 2022, following the final view in Ascent Meditech Ltd. The appellate authority's failure to consider that notification and the related clarification rendered its rejection of the refund claims unsustainable. On a composite reading of Section 54(3) and the Rules, the petitioner was entitled to refund of accumulated input tax credit arising from the inverted duty structure, and the original and appellate rejection orders were quashed.
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