Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Grant-in-aid from CCRAS was treated as consideration because the payments were linked to approved proposals, deliverables, reporting, audits and specified research work, and the subsidy exclusion for Government grants did not extend by implication. The appellant and CCRAS were separate legal persons, so the research work constituted supply between distinct taxable persons in the course of business, and the appellant was not a pure agent. Exemption under Entries 3 and 3A was denied because the services were research and documentation for a central research body, not functions entrusted to Panchayat or Municipality bodies. The work was classified as taxable research and development services under Heading 9981, and the appeal was rejected.
Grant-in-aid from CCRAS was treated as consideration because the payments were linked to approved proposals, deliverables, reporting, audits and specified research work, and the subsidy exclusion for Government grants did not extend by implication. The appellant and CCRAS were separate legal persons, so the research work constituted supply between distinct taxable persons in the course of business, and the appellant was not a pure agent. Exemption under Entries 3 and 3A was denied because the services were research and documentation for a central research body, not functions entrusted to Panchayat or Municipality bodies. The work was classified as taxable research and development services under Heading 9981, and the appeal was rejected.
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