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...
Non-generation of an e-invoice bearing IRN/QR Code before movement of goods is a procedural breach, but it does not by itself warrant detention penalty under Section 129. Where the tax invoice, e-way bill and lorry receipt identify the parties, goods, value and tax liability, and a later e-invoice matches the transaction, the lapse does not conclusively establish intent to evade tax absent fictitious documents, mismatched goods, value suppression or concealed supply. On these facts, the Section 129 penalty was unsustainable, the appellate order was set aside, and consequential relief was granted subject to statutory procedure.
Non-generation of an e-invoice bearing IRN/QR Code before movement of goods is a procedural breach, but it does not by itself warrant detention penalty under Section 129. Where the tax invoice, e-way bill and lorry receipt identify the parties, goods, value and tax liability, and a later e-invoice matches the transaction, the lapse does not conclusively establish intent to evade tax absent fictitious documents, mismatched goods, value suppression or concealed supply. On these facts, the Section 129 penalty was unsustainable, the appellate order was set aside, and consequential relief was granted subject to statutory procedure.
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TaxTMI 
TaxTMI 
of 4878 
