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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 ...
Natural gas supplied under the GSPA was held to be an inter-State sale concluded at Gadimoga in Andhra Pradesh, where delivery, measurement, title and risk passed to the buyer's designee; the subsequent movement through a common carrier pipeline into Uttar Pradesh was only transportation and did not convert the transaction into an intra-State sale. Co-mingling, re-metering, fungibility and processing during transit did not alter the sale's character, and Uttar Pradesh therefore lacked jurisdiction to levy VAT. Explanation 3 to Section 3 of the CST Act was treated as clarificatory, reflecting the pre-existing legal position and applying to the original scheme of the provision.
Natural gas supplied under the GSPA was held to be an inter-State sale concluded at Gadimoga in Andhra Pradesh, where delivery, measurement, title and risk passed to the buyer's designee; the subsequent movement through a common carrier pipeline into Uttar Pradesh was only transportation and did not convert the transaction into an intra-State sale. Co-mingling, re-metering, fungibility and processing during transit did not alter the sale's character, and Uttar Pradesh therefore lacked jurisdiction to levy VAT. Explanation 3 to Section 3 of the CST Act was treated as clarificatory, reflecting the pre-existing legal position and applying to the original scheme of the provision.
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