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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Levy of GST - transfer of development rights of land by the land owners to the petitioner by way of a Joint Development Agreement - sale of land by the land owners or not - The High court found that the transfer of development rights is a service and not an outright sale of immovable property. The JDA facilitates development but does not, in itself, transfer ownership. Thus, such transfers are subject to GST and cannot be considered under Entry 5 of Schedule-III of the GST Act. - The court upheld the constitutionality of the notification, noting that it is based on the recommendations of the GST Council and issued within the powers conferred by the GST laws and the Constitution.
Levy of GST - transfer of development rights of land by the land owners to the petitioner by way of a Joint Development Agreement - sale of land by the land owners or not - The High court found that the transfer of development rights is a service and not an outright sale of immovable property. The JDA facilitates development but does not, in itself, transfer ownership. Thus, such transfers are subject to GST and cannot be considered under Entry 5 of Schedule-III of the GST Act. - The court upheld the constitutionality of the notification, noting that it is based on the recommendations of the GST Council and issued within the powers conferred by the GST laws and the Constitution.
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