Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
SC held that issuance of summons does not amount to the "initiation of any proceedings" under Section 6(2)(b) of the CGST Act; formal initiation occurs upon service of a show cause notice delineating the subject matter. The Court construed "subject matter" as the specific tax liability, deficiency or obligation framed in adjudicatory proceedings and held that overlapping or investigative acts (summons, search, seizure) do not ipso facto create identical subject matter attracting the bar in Section 6(2)(b). Section 6(2)(a) requires a proper officer issuing an order under the CGST Act to communicate a corresponding order to the State/UT counterpart to prevent multiplicity of proceedings. Petition disposed.
SC held that issuance of summons does not amount to the "initiation of any proceedings" under Section 6(2)(b) of the CGST Act; formal initiation occurs upon service of a show cause notice delineating the subject matter. The Court construed "subject matter" as the specific tax liability, deficiency or obligation framed in adjudicatory proceedings and held that overlapping or investigative acts (summons, search, seizure) do not ipso facto create identical subject matter attracting the bar in Section 6(2)(b). Section 6(2)(a) requires a proper officer issuing an order under the CGST Act to communicate a corresponding order to the State/UT counterpart to prevent multiplicity of proceedings. Petition disposed.
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