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...
HC declared amendments to CGST and KGST Acts unconstitutional, finding retrospective modifications ultra vires the Constitution. The court held that legislative amendments improperly expanded the definition of "supply" and "service" by disregarding the principle of mutuality. The retrospective taxation violated fundamental principles of fairness and Rule of Law, as it imposed unexpected tax burdens on entities without prior notice or opportunity to adjust. The amendments were deemed void, emphasizing constitutional limitations on legislative power to redefine taxation principles retroactively. The judgment reinforced constitutional protections against arbitrary legislative interventions in taxation frameworks.
HC declared amendments to CGST and KGST Acts unconstitutional, finding retrospective modifications ultra vires the Constitution. The court held that legislative amendments improperly expanded the definition of "supply" and "service" by disregarding the principle of mutuality. The retrospective taxation violated fundamental principles of fairness and Rule of Law, as it imposed unexpected tax burdens on entities without prior notice or opportunity to adjust. The amendments were deemed void, emphasizing constitutional limitations on legislative power to redefine taxation principles retroactively. The judgment reinforced constitutional protections against arbitrary legislative interventions in taxation frameworks.
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