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 ...
Refund of accumulated input tax credit on exported goods remains available where bill-to ship-to supplies are supported by undisputed e-way bills, transportation, export and banking records establishing delivery and export. GST law does not require movement to commence from the supplier's registered premises, and toll plaza receipts are not a mandatory condition for credit; toll data cannot override documentary proof of physical movement. Cancellation of upstream suppliers' registrations does not by itself invalidate credit where the direct supplier is validly registered and the claimant lacks involvement in upstream irregularities. Fresh allegations and unsupported evidence beyond the show cause notice cannot be raised at the Tribunal stage, absent exceptional circumstances under the applicable evidence rules.
Refund of accumulated input tax credit on exported goods remains available where bill-to ship-to supplies are supported by undisputed e-way bills, transportation, export and banking records establishing delivery and export. GST law does not require movement to commence from the supplier's registered premises, and toll plaza receipts are not a mandatory condition for credit; toll data cannot override documentary proof of physical movement. Cancellation of upstream suppliers' registrations does not by itself invalidate credit where the direct supplier is validly registered and the claimant lacks involvement in upstream irregularities. Fresh allegations and unsupported evidence beyond the show cause notice cannot be raised at the Tribunal stage, absent exceptional circumstances under the applicable evidence rules.
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