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Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
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Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
The High Court dismissed the appeals filed by the Revenue as withdrawn, holding that the appeals did not fall under the exception carved out in Circular No. 3.1(l) dated 15.03.2024. The Court ruled that the exception in Clause 3.1(l) applies only to cases where the deductor failed to deduct tax at source and the tax was sought to be recovered from the payer. However, in the present case, the issue pertained to the disallowance of expenses claimed by the assessee due to non-deduction of tax at source u/s 195. The Court clarified that litigation arising from regular assessments u/s 143(3) and failure to deduct tax at source are treated separately under the Act. Consequently, the enhanced monetary limits specified in the Circular applied retrospectively, rendering the tax effect in the appeals below the prescribed threshold, leading to their dismissal.
The High Court dismissed the appeals filed by the Revenue as withdrawn, holding that the appeals did not fall under the exception carved out in Circular No. 3.1(l) dated 15.03.2024. The Court ruled that the exception in Clause 3.1(l) applies only to cases where the deductor failed to deduct tax at source and the tax was sought to be recovered from the payer. However, in the present case, the issue pertained to the disallowance of expenses claimed by the assessee due to non-deduction of tax at source u/s 195. The Court clarified that litigation arising from regular assessments u/s 143(3) and failure to deduct tax at source are treated separately under the Act. Consequently, the enhanced monetary limits specified in the Circular applied retrospectively, rendering the tax effect in the appeals below the prescribed threshold, leading to their dismissal.
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