Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Whether the impugned supplies qualified as export of services under Section 2(6) IGST and whether the petitioner was an "intermediary" under Section 13(2)/place of supply under Section 13(8)(b) was the dominant issue. The court held the authorities failed to make requisite findings on (a) existence of a third party intermeddling in transactions, (b) whether supplies were between two principals or by the petitioner on its own account, and (c) whether the petitioner merely arranged/facilitated supplies; their orders were cryptic and showed non-application of mind. Consequence: impugned orders set aside and matter remanded to appellate and refund sanctioning authorities for fresh decision. - HC
Whether the impugned supplies qualified as export of services under Section 2(6) IGST and whether the petitioner was an "intermediary" under Section 13(2)/place of supply under Section 13(8)(b) was the dominant issue. The court held the authorities failed to make requisite findings on (a) existence of a third party intermeddling in transactions, (b) whether supplies were between two principals or by the petitioner on its own account, and (c) whether the petitioner merely arranged/facilitated supplies; their orders were cryptic and showed non-application of mind. Consequence: impugned orders set aside and matter remanded to appellate and refund sanctioning authorities for fresh decision. - HC
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