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...
Pre-movement e-way bill compliance requires the e-way bill to be generated before goods begin moving, with the tax invoice and e-way bill carried by the person in charge. Generating those documents only after interception does not cure transportation undertaken without them. Their absence at interception creates a rebuttable presumption of intent to evade tax, which may be displaced only by a reasonable explanation. The explanation did not rebut that presumption, and the detention-related penalty under section 129 was sustained.
Pre-movement e-way bill compliance requires the e-way bill to be generated before goods begin moving, with the tax invoice and e-way bill carried by the person in charge. Generating those documents only after interception does not cure transportation undertaken without them. Their absence at interception creates a rebuttable presumption of intent to evade tax, which may be displaced only by a reasonable explanation. The explanation did not rebut that presumption, and the detention-related penalty under section 129 was sustained.
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