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...
Writ challenges to licence notices and tender conditions became infructuous after the licence period expired, so no effective relief could be granted on those issues. GST demands raised under reverse charge on 99% of the licence fee were unsustainable because TASMAC is a distinct juristic entity and not the State Government, Union Territory or local authority for the relevant notifications; the reverse charge entry therefore did not apply. The assessment orders and show cause notice on that basis were quashed. The Court left open independent GST liability, if any, on the petitioners' own supplies and permitted fresh proceedings under the machinery for unregistered persons, subject to limitation.
Writ challenges to licence notices and tender conditions became infructuous after the licence period expired, so no effective relief could be granted on those issues. GST demands raised under reverse charge on 99% of the licence fee were unsustainable because TASMAC is a distinct juristic entity and not the State Government, Union Territory or local authority for the relevant notifications; the reverse charge entry therefore did not apply. The assessment orders and show cause notice on that basis were quashed. The Court left open independent GST liability, if any, on the petitioners' own supplies and permitted fresh proceedings under the machinery for unregistered persons, subject to limitation.
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