Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Consistent treatment of identical export services is central to refund eligibility for unutilised input tax credit on zero-rated supplies. The note states that services granted refunds in periods before and after the disputed period should not be classified as intermediary services for the intervening period without material distinguishing their nature. Such differential classification is described as arbitrary, discriminatory and contrary to the principle of consistency. It records that rejection of the refund claim was set aside and release of the refund with applicable interest was directed.
Consistent treatment of identical export services is central to refund eligibility for unutilised input tax credit on zero-rated supplies. The note states that services granted refunds in periods before and after the disputed period should not be classified as intermediary services for the intervening period without material distinguishing their nature. Such differential classification is described as arbitrary, discriminatory and contrary to the principle of consistency. It records that rejection of the refund claim was set aside and release of the refund with applicable interest was directed.
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