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...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Bill-to/Ship-to transactions permit an intermediate purchaser to instruct the original supplier to dispatch goods directly to the ultimate recipient, provided the supplies are genuine, documented and properly accounted for. Rule 138(2) allows the consignor or consignee causing movement to generate the e-way bill. Where e-invoices and e-way bills are generated before interception by the party arranging transport, the supplier's separate non-generation does not justify detention of goods. Compliance with these requirements makes detention and penalty for e-way bill non-compliance unsustainable.
Bill-to/Ship-to transactions permit an intermediate purchaser to instruct the original supplier to dispatch goods directly to the ultimate recipient, provided the supplies are genuine, documented and properly accounted for. Rule 138(2) allows the consignor or consignee causing movement to generate the e-way bill. Where e-invoices and e-way bills are generated before interception by the party arranging transport, the supplier's separate non-generation does not justify detention of goods. Compliance with these requirements makes detention and penalty for e-way bill non-compliance unsustainable.
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