Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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