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...
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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