Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
The note examines sustainability of composite notices issued under the CGST/SGST scheme for multiple assessment years, holding that the concept of a "valid return" and the limitation linked to the financial year constrain multi year adjudication. It recognises that officers may investigate instances spanning years but stresses that consolidated adjudication can prejudice the taxpayer; therefore impugned multi year notices were quashed with liberty to issue fresh, year wise notices and with the pendency period excluded from limitation while other contentions remain open.
The note examines sustainability of composite notices issued under the CGST/SGST scheme for multiple assessment years, holding that the concept of a "valid return" and the limitation linked to the financial year constrain multi year adjudication. It recognises that officers may investigate instances spanning years but stresses that consolidated adjudication can prejudice the taxpayer; therefore impugned multi year notices were quashed with liberty to issue fresh, year wise notices and with the pendency period excluded from limitation while other contentions remain open.
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