Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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