Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Where a single contract separately itemises remuneration for Clearing & Forwarding (C&F) services and transportation, the services are distinct; transportation qualifies as Goods Transport Agency (GTA) services and attracts reverse charge liability on the service recipient. Applying statutory scheme and Service Tax Rules, Rule 2(1)(d)(d), transportation charges expressly stated for GTA cannot be included in the assessable value of C&F services to avoid double taxation. The tribunal applied prior authorities and administrative instructions and set aside the demand, holding that separately charged GTA consideration is outside C&F taxable value.
Where a single contract separately itemises remuneration for Clearing & Forwarding (C&F) services and transportation, the services are distinct; transportation qualifies as Goods Transport Agency (GTA) services and attracts reverse charge liability on the service recipient. Applying statutory scheme and Service Tax Rules, Rule 2(1)(d)(d), transportation charges expressly stated for GTA cannot be included in the assessable value of C&F services to avoid double taxation. The tribunal applied prior authorities and administrative instructions and set aside the demand, holding that separately charged GTA consideration is outside C&F taxable value.
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