Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Refund of amount deposited during investigation proceedings - voluntary deposit or not - Recovery of wrongful input tax credit - The Court found that in the instant case, the deposit made by the Petitioner was at 3:10 and 3:18 AM during the search operation being carried out which continued till 5:00 AM The fact that Petitioner was made to deposit the amount at 3:10 and 3:18 AM before the search ended and the officers left at 5:00 AM, shows that the deposit was not voluntary and contrary to the CBIC Instruction No. 01/2022-2023 dated 25.05.2022. - The Court orders refund of the deposited amount with interest, and re-crediting of Electronic Credit Ledger.
Refund of amount deposited during investigation proceedings - voluntary deposit or not - Recovery of wrongful input tax credit - The Court found that in the instant case, the deposit made by the Petitioner was at 3:10 and 3:18 AM during the search operation being carried out which continued till 5:00 AM The fact that Petitioner was made to deposit the amount at 3:10 and 3:18 AM before the search ended and the officers left at 5:00 AM, shows that the deposit was not voluntary and contrary to the CBIC Instruction No. 01/2022-2023 dated 25.05.2022. - The Court orders refund of the deposited amount with interest, and re-crediting of Electronic Credit Ledger.
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