Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
HC invalidated CBDT Circular No. 07/2007's paragraph 9 as ultra vires, ruling it exceeded powers under Section 119. Court found refund applications for excess tax deducted under Section 195 were wrongly rejected on limitation grounds. Following S.A. Builders precedent on commercial expediency, HC determined that borrowings through FCCBs and ECBs used for overseas holding company qualified as debt incurred for earning foreign income. The expenditure met commercial expediency test as investments were motivated by expectation of foreign source income. Court directed refund of excess taxes deposited for FY 2010-11 to 2012-13, rejecting revenue's interpretation of Section 9(1)(v)(b) as unsustainable.
HC invalidated CBDT Circular No. 07/2007's paragraph 9 as ultra vires, ruling it exceeded powers under Section 119. Court found refund applications for excess tax deducted under Section 195 were wrongly rejected on limitation grounds. Following S.A. Builders precedent on commercial expediency, HC determined that borrowings through FCCBs and ECBs used for overseas holding company qualified as debt incurred for earning foreign income. The expenditure met commercial expediency test as investments were motivated by expectation of foreign source income. Court directed refund of excess taxes deposited for FY 2010-11 to 2012-13, rejecting revenue's interpretation of Section 9(1)(v)(b) as unsustainable.
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