Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Pigmy agents engaged by a bank were treated as employees because the relationship was marked by pervasive control, supervision and disciplinary oversight, with commission functioning in substance as wages. Their services rendered in the course of employment fell within Schedule III read with section 7(2)(a) of the GST law and were therefore neither a supply of goods nor a supply of services. The attempt to classify them as business facilitators liable under reverse charge was rejected, and the show cause notices were quashed for proceeding on an erroneous jurisdictional basis. The challenge to the limitation-extension notifications was left open.
Pigmy agents engaged by a bank were treated as employees because the relationship was marked by pervasive control, supervision and disciplinary oversight, with commission functioning in substance as wages. Their services rendered in the course of employment fell within Schedule III read with section 7(2)(a) of the GST law and were therefore neither a supply of goods nor a supply of services. The attempt to classify them as business facilitators liable under reverse charge was rejected, and the show cause notices were quashed for proceeding on an erroneous jurisdictional basis. The challenge to the limitation-extension notifications was left open.
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