Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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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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