Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.
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