Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
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