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...
An electronic platform that connects transporters with customers, without itself undertaking transportation, issuing consignment notes, or performing ancillary transport functions, is an electronic commerce operator and not a goods transport agency. It also does not qualify as an agent or pure agent where it merely facilitates bookings and lacks the contractual conditions required under Rule 33. The exemption for transportation of goods by road was therefore unavailable. GST was held payable on the commission earned from transporters, and the operator was required to comply with tax collection at source under the e-commerce framework. The deeming liability for notified services supplied through e-commerce operators did not apply to transportation services.
An electronic platform that connects transporters with customers, without itself undertaking transportation, issuing consignment notes, or performing ancillary transport functions, is an electronic commerce operator and not a goods transport agency. It also does not qualify as an agent or pure agent where it merely facilitates bookings and lacks the contractual conditions required under Rule 33. The exemption for transportation of goods by road was therefore unavailable. GST was held payable on the commission earned from transporters, and the operator was required to comply with tax collection at source under the e-commerce framework. The deeming liability for notified services supplied through e-commerce operators did not apply to transportation services.
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