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 held that amendments to CGST and KGST Acts regarding deemed supply of services by clubs/associations to members are unconstitutional. The court determined that the principle of mutuality survives constitutional interpretation, and the retrospective amendments violate the Rule of Law. The statutory provisions improperly expanded the definition of "supply" and "service" without constitutional basis. The amendments were declared void, with the court emphasizing that legislative actions must respect fairness and cannot impose unexpected tax liabilities retrospectively. The judgment upholds the principle that taxation mechanisms cannot arbitrarily redefine fundamental legal concepts without appropriate constitutional amendments.
HC held that amendments to CGST and KGST Acts regarding deemed supply of services by clubs/associations to members are unconstitutional. The court determined that the principle of mutuality survives constitutional interpretation, and the retrospective amendments violate the Rule of Law. The statutory provisions improperly expanded the definition of "supply" and "service" without constitutional basis. The amendments were declared void, with the court emphasizing that legislative actions must respect fairness and cannot impose unexpected tax liabilities retrospectively. The judgment upholds the principle that taxation mechanisms cannot arbitrarily redefine fundamental legal concepts without appropriate constitutional amendments.
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