Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Consignment value for goods returned by a job worker comprises the job-work charges and applicable tax, not the value of the principal's goods. Under section 15 read with Explanation 2 to Rule 138, the return movement represents the job-work service; where its taxable value is below the prescribed threshold, an e-way bill is not mandatory. Detention and penalty action cannot rest on allegations contradicted by departmental records, including the presence of a tax-paid job-work invoice, delivery challan and e-way bill. A detention or appellate order must remain within the show-cause notice's factual allegations and give reasons for treating an e-way bill as invalid; reliance on unalleged grounds breaches natural justice.
Consignment value for goods returned by a job worker comprises the job-work charges and applicable tax, not the value of the principal's goods. Under section 15 read with Explanation 2 to Rule 138, the return movement represents the job-work service; where its taxable value is below the prescribed threshold, an e-way bill is not mandatory. Detention and penalty action cannot rest on allegations contradicted by departmental records, including the presence of a tax-paid job-work invoice, delivery challan and e-way bill. A detention or appellate order must remain within the show-cause notice's factual allegations and give reasons for treating an e-way bill as invalid; reliance on unalleged grounds breaches natural justice.
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