Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Services of facilitating Indian students' admissions to foreign universities through a foreign entity were examined to determine whether they constituted "export of services" and whether the supplier qualified as an "intermediary" under the IGST Act. Relying on bindingly persuasive precedents holding that identical facilitation services are not intermediary services and therefore qualify for export treatment, and noting that those decisions had attained finality and were implemented, the Court held the supplier was not an intermediary, making GST demand unsustainable. Consequently, the show-cause notice and the impugned order were quashed, and the matter was remitted for processing the refund with applicable interest within four weeks. - HC
Services of facilitating Indian students' admissions to foreign universities through a foreign entity were examined to determine whether they constituted "export of services" and whether the supplier qualified as an "intermediary" under the IGST Act. Relying on bindingly persuasive precedents holding that identical facilitation services are not intermediary services and therefore qualify for export treatment, and noting that those decisions had attained finality and were implemented, the Court held the supplier was not an intermediary, making GST demand unsustainable. Consequently, the show-cause notice and the impugned order were quashed, and the matter was remitted for processing the refund with applicable interest within four weeks. - HC
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