Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Parallel proceedings are barred only when they seek to assess or recover the same liability arising from the same contravention. Applying that principle, the Court found no overlap between a proceeding for short payment of tax based on GSTR-1 and GSTR-3B and a later notice for excess input tax credit claimed on invoices not reflected in GSTR-2A. The two actions concerned distinct infractions, even though they related to the same tax period. The challenge on overlapping subject matter therefore failed, and the petitioner was left to pursue the statutory appeal with all grounds kept open.
Parallel proceedings are barred only when they seek to assess or recover the same liability arising from the same contravention. Applying that principle, the Court found no overlap between a proceeding for short payment of tax based on GSTR-1 and GSTR-3B and a later notice for excess input tax credit claimed on invoices not reflected in GSTR-2A. The two actions concerned distinct infractions, even though they related to the same tax period. The challenge on overlapping subject matter therefore failed, and the petitioner was left to pursue the statutory appeal with all grounds kept open.
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