Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Alleged re-use of an e-way bill and intent to evade tax require cogent evidence; toll-plaza movement records, photographs, and suspicion cannot replace proof. Where accompanying invoices, e-invoices, and e-way bills show no discrepancy in the goods' description, quantity, value, or ownership, and no independent evidence proves an earlier completed journey or delivery, the contravention remains unproved. Failure to verify material showing that a prior trip carried different goods further undermines the allegation. Detention-based tax and penalty were set aside, with refund of deposited amounts in accordance with law.
Alleged re-use of an e-way bill and intent to evade tax require cogent evidence; toll-plaza movement records, photographs, and suspicion cannot replace proof. Where accompanying invoices, e-invoices, and e-way bills show no discrepancy in the goods' description, quantity, value, or ownership, and no independent evidence proves an earlier completed journey or delivery, the contravention remains unproved. Failure to verify material showing that a prior trip carried different goods further undermines the allegation. Detention-based tax and penalty were set aside, with refund of deposited amounts in accordance with law.
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