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Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Net ITC for refund of unutilised Compensation Cess credit on zero-rated supplies is confined to input tax credit actually availed and attributable to the relevant refund period. A reversal recorded in that period need not reduce Net ITC where records establish that it relates to residual unutilised credit from earlier tax periods and was not included in the credit supporting the refund claim. Paragraph 43(c) of the departmental circular must operate consistently with the statutory refund formula and cannot require deduction of every reversal reported during the period, thereby curtailing a statutory refund entitlement.
Net ITC for refund of unutilised Compensation Cess credit on zero-rated supplies is confined to input tax credit actually availed and attributable to the relevant refund period. A reversal recorded in that period need not reduce Net ITC where records establish that it relates to residual unutilised credit from earlier tax periods and was not included in the credit supporting the refund claim. Paragraph 43(c) of the departmental circular must operate consistently with the statutory refund formula and cannot require deduction of every reversal reported during the period, thereby curtailing a statutory refund entitlement.
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