Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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Construction for educational institutions and public welfare projects was treated as non-commercial: works for a charitable medical college, police housing and allied welfare facilities did not become taxable merely because fees were collected, incidental revenue arose, or a small shopping or canteen component existed. An accepted VCES declaration could not be reopened as "substantially false" merely because the Department later took a different valuation or interpretational view, so finality attached to the declaration. On limitation and penalty, minor reconciliation differences between the profit and loss account and ST-3 returns, together with payment before notice and absence of suppression, defeated extended limitation and consequential penalties; only the admitted balance manpower-supply liability survived with interest, subject to limitation.
Construction for educational institutions and public welfare projects was treated as non-commercial: works for a charitable medical college, police housing and allied welfare facilities did not become taxable merely because fees were collected, incidental revenue arose, or a small shopping or canteen component existed. An accepted VCES declaration could not be reopened as "substantially false" merely because the Department later took a different valuation or interpretational view, so finality attached to the declaration. On limitation and penalty, minor reconciliation differences between the profit and loss account and ST-3 returns, together with payment before notice and absence of suppression, defeated extended limitation and consequential penalties; only the admitted balance manpower-supply liability survived with interest, subject to limitation.
Note: It is a system-generated summary and is for quick reference only.