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Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Fresh GST adjudication was required where the taxpayer asserted that tax liability had already been discharged and that the final demand components overlapped with an assessment by the jurisdictional officer. The assessment was quashed and remitted for a fresh merits decision after notice, conditional on deposit of interest and penalty imposed in the earlier jurisdictional assessment. Failure to make that deposit permitted recovery in accordance with law.
Fresh GST adjudication was required where the taxpayer asserted that tax liability had already been discharged and that the final demand components overlapped with an assessment by the jurisdictional officer. The assessment was quashed and remitted for a fresh merits decision after notice, conditional on deposit of interest and penalty imposed in the earlier jurisdictional assessment. Failure to make that deposit permitted recovery in accordance with law.
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