Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Non-reporting of an international transaction may attract penalty under section 271AA, but a bona fide belief based on reasonable cause can exclude liability where the transaction has no effective nexus with an Indian project office or permanent establishment, no related income is attributed to India, and the transaction is accepted at arm's length. The notes state that penalty for a Korean sale of raw materials to an Indian associated enterprise was deleted on this basis. They further explain that appellate enhancement cannot introduce transactions outside the scope of the original penalty proceedings. Enhancement relating to guarantee fees and trade affairs services was therefore unsustainable because initiation had concerned only the raw-material sale.
Non-reporting of an international transaction may attract penalty under section 271AA, but a bona fide belief based on reasonable cause can exclude liability where the transaction has no effective nexus with an Indian project office or permanent establishment, no related income is attributed to India, and the transaction is accepted at arm's length. The notes state that penalty for a Korean sale of raw materials to an Indian associated enterprise was deleted on this basis. They further explain that appellate enhancement cannot introduce transactions outside the scope of the original penalty proceedings. Enhancement relating to guarantee fees and trade affairs services was therefore unsustainable because initiation had concerned only the raw-material sale.
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