Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
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Consignment value for goods returned by a job worker comprises the job-work charges and applicable tax, not the value of the principal's goods. Under section 15 read with Explanation 2 to Rule 138, the return movement represents the job-work service; where its taxable value is below the prescribed threshold, an e-way bill is not mandatory. Detention and penalty action cannot rest on allegations contradicted by departmental records, including the presence of a tax-paid job-work invoice, delivery challan and e-way bill. A detention or appellate order must remain within the show-cause notice's factual allegations and give reasons for treating an e-way bill as invalid; reliance on unalleged grounds breaches natural justice.
Consignment value for goods returned by a job worker comprises the job-work charges and applicable tax, not the value of the principal's goods. Under section 15 read with Explanation 2 to Rule 138, the return movement represents the job-work service; where its taxable value is below the prescribed threshold, an e-way bill is not mandatory. Detention and penalty action cannot rest on allegations contradicted by departmental records, including the presence of a tax-paid job-work invoice, delivery challan and e-way bill. A detention or appellate order must remain within the show-cause notice's factual allegations and give reasons for treating an e-way bill as invalid; reliance on unalleged grounds breaches natural justice.
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