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...
An e-way bill showing a wholly different vehicle number generated differing views on whether a penalty for tax-evasion intent could arise. The Judicial Member considered correct Part B vehicle particulars mandatory, treated post-interception correction as ineffective, and found that the circumstances created a rebuttable presumption of evasion that remained unrebutted. The Technical Member treated invoices and commercial records showing the correct vehicle as evidence of a genuine transaction, concluding that a mismatch alone, absent a finding of evasion intent, could not support penalty. The point of difference was referred to another Member; the departmental appeal remains undecided.
An e-way bill showing a wholly different vehicle number generated differing views on whether a penalty for tax-evasion intent could arise. The Judicial Member considered correct Part B vehicle particulars mandatory, treated post-interception correction as ineffective, and found that the circumstances created a rebuttable presumption of evasion that remained unrebutted. The Technical Member treated invoices and commercial records showing the correct vehicle as evidence of a genuine transaction, concluding that a mismatch alone, absent a finding of evasion intent, could not support penalty. The point of difference was referred to another Member; the departmental appeal remains undecided.
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