Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Writ jurisdiction remained available despite a statutory appellate remedy because the disputed GST classification involved an apparent jurisdictional error of law without factual dispute; the non-functionality of the Tribunal when the petitions were filed also supported intervention. Licensing of copyright in cinematographic films by the original holder was classified as intellectual-property rights in goods other than information technology software: a passive audiovisual film lacks the computer-based manipulation or interactivity required for software, and its delivery method does not alter the supply's character. Pre-1 October 2021 GST regularisation at 12% on an "as is where is" basis extended to producer-to-distributor theatrical-rights licensing and could not be confined to downstream transactions, rendering the contrary classification and demands erroneous.
Writ jurisdiction remained available despite a statutory appellate remedy because the disputed GST classification involved an apparent jurisdictional error of law without factual dispute; the non-functionality of the Tribunal when the petitions were filed also supported intervention. Licensing of copyright in cinematographic films by the original holder was classified as intellectual-property rights in goods other than information technology software: a passive audiovisual film lacks the computer-based manipulation or interactivity required for software, and its delivery method does not alter the supply's character. Pre-1 October 2021 GST regularisation at 12% on an "as is where is" basis extended to producer-to-distributor theatrical-rights licensing and could not be confined to downstream transactions, rendering the contrary classification and demands erroneous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
