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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...
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Section 129 penalties for failure to update Part-B of an e-way bill require independent findings of an intent to evade tax where the goods movement is otherwise supported by genuine tax documents. The integrated electronic GST framework distinguishes technical or procedural omissions from active tax-evasion attempts. Where the invoice, Part-A details and underlying transaction transparently establish the movement, non-updation of Part-B alone should not sustain a penalty. Strict-liability principles developed under the legacy manual check-post regime are not treated as governing such electronic GST compliance failures.
Section 129 penalties for failure to update Part-B of an e-way bill require independent findings of an intent to evade tax where the goods movement is otherwise supported by genuine tax documents. The integrated electronic GST framework distinguishes technical or procedural omissions from active tax-evasion attempts. Where the invoice, Part-A details and underlying transaction transparently establish the movement, non-updation of Part-B alone should not sustain a penalty. Strict-liability principles developed under the legacy manual check-post regime are not treated as governing such electronic GST compliance failures.
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