Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Goods detained on ground of non-generation of E-Tax Invoice as per Rule 48 of GST Rules before movement; all required documents u/r 138A accompanied goods; technical error by petitioner in not generating E-Tax Invoice; no discrepancy in quality/quantity of goods; error a human error; prior to 01.08.2022, dealers with annual turnover over Rs. 20 crores required to issue E-Waybill; in absence of finding on mens rea, proceedings u/s 129(3) cannot be initiated; impugned orders quashed; writ petition allowed.
Goods detained on ground of non-generation of E-Tax Invoice as per Rule 48 of GST Rules before movement; all required documents u/r 138A accompanied goods; technical error by petitioner in not generating E-Tax Invoice; no discrepancy in quality/quantity of goods; error a human error; prior to 01.08.2022, dealers with annual turnover over Rs. 20 crores required to issue E-Waybill; in absence of finding on mens rea, proceedings u/s 129(3) cannot be initiated; impugned orders quashed; writ petition allowed.
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