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...
Legal documentation and certification services for filing patent applications received from foreign patent attorneys constituted "legal services" classifiable under SAC 998213, attracting GST as import of services with place of supply at the recipient's location in India. Exemption for "legal services" under the relevant entry was held inapplicable because "advocate/senior advocate" under the Advocates Act, 1961 refers to persons enrolled under Indian rolls and does not extend to foreign attorneys; consequently, the services were taxable. The activity was held to be in the course or furtherance of the foreign service providers' business and therefore a "supply," making tax payable by the recipient under reverse charge as per the applicable notification. - AAR
Legal documentation and certification services for filing patent applications received from foreign patent attorneys constituted "legal services" classifiable under SAC 998213, attracting GST as import of services with place of supply at the recipient's location in India. Exemption for "legal services" under the relevant entry was held inapplicable because "advocate/senior advocate" under the Advocates Act, 1961 refers to persons enrolled under Indian rolls and does not extend to foreign attorneys; consequently, the services were taxable. The activity was held to be in the course or furtherance of the foreign service providers' business and therefore a "supply," making tax payable by the recipient under reverse charge as per the applicable notification. - AAR
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