Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Imposition of tax and penalty u/s 129(3) - e-way bill had expired nine hours and thirty minutes prior to interception - The High court referred to previous cases where mens rea to evade tax was deemed essential for penalty imposition. In the present case, the court found no evidence of intent to evade tax, as the goods were properly documented, and the delay was due to a breakdown. The court emphasized that the failure to extend the e-way bill was a technical breach and not sufficient grounds for imposing a penalty under Section 129(3) of the Act.
Imposition of tax and penalty u/s 129(3) - e-way bill had expired nine hours and thirty minutes prior to interception - The High court referred to previous cases where mens rea to evade tax was deemed essential for penalty imposition. In the present case, the court found no evidence of intent to evade tax, as the goods were properly documented, and the delay was due to a breakdown. The court emphasized that the failure to extend the e-way bill was a technical breach and not sufficient grounds for imposing a penalty under Section 129(3) of the Act.
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