Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Wrongful availment of input tax credit, where credit exceeded GSTR-2A and was utilised in GSTR-3B, was treated as prima facie suppression of facts with intent to evade tax, supporting invocation of the extended limitation under GST. The Court also noted an apparent failure to discharge reverse charge liability on commissions from foreign booking agencies. The limitation challenge was rejected as covered by the earlier Madras High Court ruling in Tata Play Limited, and the Court further observed that, for the relevant assessment years, even the period for passing orders under the lesser limitation regime had not expired. The writ petitions were dismissed, with liberty to pursue the statutory appeal on merits.
Wrongful availment of input tax credit, where credit exceeded GSTR-2A and was utilised in GSTR-3B, was treated as prima facie suppression of facts with intent to evade tax, supporting invocation of the extended limitation under GST. The Court also noted an apparent failure to discharge reverse charge liability on commissions from foreign booking agencies. The limitation challenge was rejected as covered by the earlier Madras High Court ruling in Tata Play Limited, and the Court further observed that, for the relevant assessment years, even the period for passing orders under the lesser limitation regime had not expired. The writ petitions were dismissed, with liberty to pursue the statutory appeal on merits.
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