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 penalties for an unfilled Part-B of an e-way bill require independent, recorded evidence of intent to evade tax; a technical or clerical omission alone is insufficient where invoices, Part-A particulars and other documentation establish a transparent, tax-paid transaction. Penalties imposed without positive proof of tax-evasion intent are legally unsustainable. Following detention and consideration of objections, a final reasoned order in Form GST MOV-09 must be issued after providing a hearing. Failure to issue that speaking order prejudices the taxpayer's rights and vitiates the resulting penalty demand.
Section 129 penalties for an unfilled Part-B of an e-way bill require independent, recorded evidence of intent to evade tax; a technical or clerical omission alone is insufficient where invoices, Part-A particulars and other documentation establish a transparent, tax-paid transaction. Penalties imposed without positive proof of tax-evasion intent are legally unsustainable. Following detention and consideration of objections, a final reasoned order in Form GST MOV-09 must be issued after providing a hearing. Failure to issue that speaking order prejudices the taxpayer's rights and vitiates the resulting penalty demand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
