GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Composite engineering assignments involving drawing assistance, development, technical clarification, material specifications, quality coordination and dispatch assistance are classifiable by their essential character as Consulting Engineer Service, rather than Technical Inspection and Certification Service where inspection is only incidental and independently uncharged. Services supplied to a foreign contractual recipient for convertible foreign exchange qualify as exports where the recipient is the user; physical performance in India does not displace export treatment. From 1 July 2012, the physical-availability-of-goods rule applies only when goods must be physically available to provide the service, so the foreign recipient's location governs otherwise. Extended limitation requires wilful suppression or contravention with intent to evade tax and cannot rest on a later departmental view after relevant disclosures.
Composite engineering assignments involving drawing assistance, development, technical clarification, material specifications, quality coordination and dispatch assistance are classifiable by their essential character as Consulting Engineer Service, rather than Technical Inspection and Certification Service where inspection is only incidental and independently uncharged. Services supplied to a foreign contractual recipient for convertible foreign exchange qualify as exports where the recipient is the user; physical performance in India does not displace export treatment. From 1 July 2012, the physical-availability-of-goods rule applies only when goods must be physically available to provide the service, so the foreign recipient's location governs otherwise. Extended limitation requires wilful suppression or contravention with intent to evade tax and cannot rest on a later departmental view after relevant disclosures.
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