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    October 7, 2026   Notes GST
    Inverted-duty ITC refunds cover higher-rated component inputs, not just principal materials, subject to statutory exclusions and formula-based limits.
    October 7, 2026   Notes GST
    Statutory timing for GST detention: delayed penalty orders are invalid despite administrative obstacles or intervening regulatory action.
    October 7, 2026   Notes GST
    Supplier tax payment remains a cumulative input tax credit condition, while reversal demands require transaction-specific evidence and reasons.
    October 7, 2026   Notes GST
    Vested appellate rights protect penalty-only GST appeals from later pre-deposit burdens when adjudication began before amendment.
    October 7, 2026   Notes GST
    Section 74 extended limitation requires pleaded facts establishing fraud, wilful misstatement or suppression, not a mere tax mismatch.
    October 7, 2026   Case Laws GST
    Interest on wrongly availed and utilised input tax credit runs from actual utilisation until reversal under GST rules.
    October 7, 2026   Case Laws GST
    Natural justice in GST appeals requires hearings and reasoned orders; non-prosecution cannot end appeals without merits review.
    October 7, 2026   Case Laws Customs
    Alternative statutory remedy governs Customs adjudication challenges after orders, making writ relief on securities and assessments unavailable.
    October 7, 2026   Case Laws IBC
    Irrevocable joint development rights prevented land exclusion from CIRP, requiring status quo pending appellate disposal.
    October 7, 2026   Case Laws Money Laundering
    Special bail treatment for women accused of money laundering permits departure from twin conditions, subject to case-specific judicial discretion.
    October 7, 2026   Case Laws GST
    Portal service of GST show cause notices requires effective intimation; absent notice invalidates adjudication and requires fresh hearing.
    October 7, 2026   Case Laws GST
    Input Tax Credit reconciliation requires examination of return records before excess-credit demands are reconsidered and bank attachments released.
    October 7, 2026   Case Laws GST
    Statutory limitation bars appellate condonation beyond the prescribed outer limit, but implemented registration restoration made departmental challeng...
    October 7, 2026   Case Laws Customs
    Temporal application of customs exemptions protects pre-amendment multimodal consignments from denial of provisional release consideration.
    October 7, 2026   Case Laws Customs
    Appellate jurisdiction over baggage imports is excluded, requiring confiscation challenges involving passenger-carried gold to proceed by statutory re...
    October 7, 2026   Case Laws IBC
    Article 227 review permits intervention in arbitration only for manifest, patent inherent jurisdictional defects, not representational authority dispu...
    October 7, 2026   Case Laws IBC
    Section 32A immunity protects successor companies from pre-CIRP corporate offences after approved resolution plans change management or control.
    October 7, 2026   Case Laws IBC
    Tribunal leave for proceedings against a company in liquidation is mandatory where the suit seeks joint reliefs.
    October 7, 2026   Case Laws IBC
    Locus Standi of Non-Parties Limits Recall of Resolution-Plan Implementation Orders and Supports Time Exclusion for Delayed Possession
    October 7, 2026   Case Laws IBC
    Shareholder standing in resolution-plan appeals excludes challenges based solely on shareholding, and unsupported fraud claims cannot cure the defect.
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October 7, 2026   Notes GST
Inverted-duty ITC refunds cover higher-rated component inputs, not just principal materials, subject to statutory exclusions and formula-based limits.
October 7, 2026   Notes GST
Statutory timing for GST detention: delayed penalty orders are invalid despite administrative obstacles or intervening regulatory action.
October 7, 2026   Notes GST
Supplier tax payment remains a cumulative input tax credit condition, while reversal demands require transaction-specific evidence and reasons.
October 7, 2026   Notes GST
Vested appellate rights protect penalty-only GST appeals from later pre-deposit burdens when adjudication began before amendment.
October 7, 2026   Notes GST
Section 74 extended limitation requires pleaded facts establishing fraud, wilful misstatement or suppression, not a mere tax mismatch.
October 7, 2026   Case Laws GST
Interest on wrongly availed and utilised input tax credit runs from actual utilisation until reversal under GST rules.
October 7, 2026   Case Laws GST
Natural justice in GST appeals requires hearings and reasoned orders; non-prosecution cannot end appeals without merits review.
October 7, 2026   Case Laws Customs
Alternative statutory remedy governs Customs adjudication challenges after orders, making writ relief on securities and assessments unavailable.
October 7, 2026   Case Laws IBC
Irrevocable joint development rights prevented land exclusion from CIRP, requiring status quo pending appellate disposal.
October 7, 2026   Case Laws Money Laundering
Special bail treatment for women accused of money laundering permits departure from twin conditions, subject to case-specific judicial discretion.
October 7, 2026   Case Laws GST
Portal service of GST show cause notices requires effective intimation; absent notice invalidates adjudication and requires fresh hearing.
October 7, 2026   Case Laws GST
Input Tax Credit reconciliation requires examination of return records before excess-credit demands are reconsidered and bank attachments released.
October 7, 2026   Case Laws GST
Statutory limitation bars appellate condonation beyond the prescribed outer limit, but implemented registration restoration made departmental challenges infructuous.
October 7, 2026   Case Laws Customs
Temporal application of customs exemptions protects pre-amendment multimodal consignments from denial of provisional release consideration.
October 7, 2026   Case Laws Customs
Appellate jurisdiction over baggage imports is excluded, requiring confiscation challenges involving passenger-carried gold to proceed by statutory revision.
October 7, 2026   Case Laws IBC
Article 227 review permits intervention in arbitration only for manifest, patent inherent jurisdictional defects, not representational authority disputes.
October 7, 2026   Case Laws IBC
Section 32A immunity protects successor companies from pre-CIRP corporate offences after approved resolution plans change management or control.
October 7, 2026   Case Laws IBC
Tribunal leave for proceedings against a company in liquidation is mandatory where the suit seeks joint reliefs.
October 7, 2026   Case Laws IBC
Locus Standi of Non-Parties Limits Recall of Resolution-Plan Implementation Orders and Supports Time Exclusion for Delayed Possession
October 7, 2026   Case Laws IBC
Shareholder standing in resolution-plan appeals excludes challenges based solely on shareholding, and unsupported fraud claims cannot cure the defect.

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Home › Highlights › Income Tax › 2023 › August, 2023 › This
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Income Tax

Income taxable in India - Fixed place PE in India - project...

Indian Income Tax: Offshore Supply Profits Not Attributable to Project Office Lacking Permanent Establishment Status Under BTIL.

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Income Tax August 22, 2023 Case Laws AT
Income taxable in India - Fixed place PE in India - project office in India - none of the conditions of fixed place PE stand satisfied - the attribution of profit qua the receipts from offshore supplies to the alleged fixed place PE in the form of BTIL is unsustainable as, in our view, BTIL cannot be construed as PE of the assessee in India. - AT
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