Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Royalty payable for a State Government grant of mineral extraction rights under a Short-Term Permit is contractual consideration for licensing services involving the right to use minerals, rather than a tax. The permit holder, as recipient of a Government-to-business supply, must discharge GST under reverse charge at 18%. The shorter duration and restricted area of a Short-Term Permit do not change the nature of the supply where the grantor, extraction rights and royalty basis correspond to those for quarry and mining leases. Short-Term Permit holders therefore receive the same reverse-charge GST treatment as quarry and mining lease holders.
Royalty payable for a State Government grant of mineral extraction rights under a Short-Term Permit is contractual consideration for licensing services involving the right to use minerals, rather than a tax. The permit holder, as recipient of a Government-to-business supply, must discharge GST under reverse charge at 18%. The shorter duration and restricted area of a Short-Term Permit do not change the nature of the supply where the grantor, extraction rights and royalty basis correspond to those for quarry and mining leases. Short-Term Permit holders therefore receive the same reverse-charge GST treatment as quarry and mining lease holders.
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