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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
An electronic GST penalty order was upheld despite not separately displaying a DIN because it carried a portal-verifiable RFN and had been served through statutory modes recognised under section 169, including the common portal, registered post and e-mail. The Court held that a challenge based only on the absence of the DIN label could not succeed where the communication was traceable and authentic, and relied on the CBIC circular dated 09.06.2025 clarifying that portal-generated communications with a verifiable RFN do not require a separate DIN. The writ petition was dismissed, with liberty to pursue the statutory appeal and exclusion of writ time for limitation purposes.
An electronic GST penalty order was upheld despite not separately displaying a DIN because it carried a portal-verifiable RFN and had been served through statutory modes recognised under section 169, including the common portal, registered post and e-mail. The Court held that a challenge based only on the absence of the DIN label could not succeed where the communication was traceable and authentic, and relied on the CBIC circular dated 09.06.2025 clarifying that portal-generated communications with a verifiable RFN do not require a separate DIN. The writ petition was dismissed, with liberty to pursue the statutory appeal and exclusion of writ time for limitation purposes.
Note: It is a system-generated summary and is for quick reference only.