Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
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Retrospective applicability of the amended Rule 89(5) governing refund of unutilised input tax credit on input services was treated as settled: the Court noted the Supreme Court's ruling in VKC Footsteps and the coordinate bench view in Ascent Meditech that Notification No. 14/2022 is retrospective, curative and clarificatory. As that legal position was undisputed, the deficiency memo rejecting the refund claim could not stand. The refund application was required to be processed under the amended formula and the law as declared.
Retrospective applicability of the amended Rule 89(5) governing refund of unutilised input tax credit on input services was treated as settled: the Court noted the Supreme Court's ruling in VKC Footsteps and the coordinate bench view in Ascent Meditech that Notification No. 14/2022 is retrospective, curative and clarificatory. As that legal position was undisputed, the deficiency memo rejecting the refund claim could not stand. The refund application was required to be processed under the amended formula and the law as declared.
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