Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 129 penalty for an expired e-way bill must serve its tax-evasion prevention purpose, notwithstanding that the provision does not expressly require mens rea. Board instructions identifying situations in which section 129 need not be invoked bind the proper officer. Where goods matched the e-way bill and delivery challan, and an erroneous consignor PIN code shortened rather than extended validity, the lapse was clerical. Without any allegation of intent to evade tax, detention and penalty proceedings under section 129 were unwarranted.
Section 129 penalty for an expired e-way bill must serve its tax-evasion prevention purpose, notwithstanding that the provision does not expressly require mens rea. Board instructions identifying situations in which section 129 need not be invoked bind the proper officer. Where goods matched the e-way bill and delivery challan, and an erroneous consignor PIN code shortened rather than extended validity, the lapse was clerical. Without any allegation of intent to evade tax, detention and penalty proceedings under section 129 were unwarranted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
