Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
A HC held that the retrospective insertion of Section 16(5), with a non obstante clause overriding Section 16(4), permitted a registered person to avail input tax credit for the specified financial years if the Section 39 return was filed up to 30.11.2021. Because the return here had been filed on 28.11.2020 for the January to March 2020 period, the claim fell within that extended statutory window and could not be rejected as time-barred under Section 16(4). The impugned order and summary order were set aside, and the matter was remitted for fresh adjudication under Section 16(5), leaving other contentions open.
A HC held that the retrospective insertion of Section 16(5), with a non obstante clause overriding Section 16(4), permitted a registered person to avail input tax credit for the specified financial years if the Section 39 return was filed up to 30.11.2021. Because the return here had been filed on 28.11.2020 for the January to March 2020 period, the claim fell within that extended statutory window and could not be rejected as time-barred under Section 16(4). The impugned order and summary order were set aside, and the matter was remitted for fresh adjudication under Section 16(5), leaving other contentions open.
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