Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Classification of e-commerce fulfilment activity turned on commercial substance, not contractual labels. The Appellate Authority found that hub-based collection, sorting, transshipment, tracking and last-mile doorstep delivery had the characteristics of organised courier and logistics operations, so the activity was not a genuine goods transport agency service despite a consignment note and separate recovery of transport charges. It also held that no independent transportation contract existed between the platform customer and the service provider, so the customer could not be treated as the recipient of GTA service. Exemption for GTA service to unregistered recipients was therefore unavailable, and the supply was liable to GST as a taxable courier/logistics/fulfilment service.
Classification of e-commerce fulfilment activity turned on commercial substance, not contractual labels. The Appellate Authority found that hub-based collection, sorting, transshipment, tracking and last-mile doorstep delivery had the characteristics of organised courier and logistics operations, so the activity was not a genuine goods transport agency service despite a consignment note and separate recovery of transport charges. It also held that no independent transportation contract existed between the platform customer and the service provider, so the customer could not be treated as the recipient of GTA service. Exemption for GTA service to unregistered recipients was therefore unavailable, and the supply was liable to GST as a taxable courier/logistics/fulfilment service.
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