Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Retrospective contractual price escalation fixes the true value of pre-GST clearances from their original clearance date. Section 142(2)(a) permits GST-compliant debit notes and post-transition reporting of differential tax, but does not create a new taxable event or defer accrual of the enhanced value. Differential tax on the increased value is therefore due from inception, making statutory interest mandatory despite the absence of formal provisional assessment. Penalty under section 122 is not warranted where the differential tax is voluntarily paid after price finalisation under a bona fide understanding of complex transitional provisions, without suppression, fraud, wilful misstatement or deliberate evasion.
Retrospective contractual price escalation fixes the true value of pre-GST clearances from their original clearance date. Section 142(2)(a) permits GST-compliant debit notes and post-transition reporting of differential tax, but does not create a new taxable event or defer accrual of the enhanced value. Differential tax on the increased value is therefore due from inception, making statutory interest mandatory despite the absence of formal provisional assessment. Penalty under section 122 is not warranted where the differential tax is voluntarily paid after price finalisation under a bona fide understanding of complex transitional provisions, without suppression, fraud, wilful misstatement or deliberate evasion.
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