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Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
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Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Section 67(2) of the CGST Act does not permit seizure of cash or securities merely because they are found during a GST search. Goods excludes money and securities, and the residuary expression "things" cannot be used to include items expressly excluded from goods. Cash being allegedly unaccounted, or an unsatisfactory explanation of its source, does not by itself establish the necessary nexus with GST proceedings. Money seized without authority must be returned or refunded. Interest and compensation for the unlawful seizure were not awarded, and other remedies remain available in law.
Section 67(2) of the CGST Act does not permit seizure of cash or securities merely because they are found during a GST search. Goods excludes money and securities, and the residuary expression "things" cannot be used to include items expressly excluded from goods. Cash being allegedly unaccounted, or an unsatisfactory explanation of its source, does not by itself establish the necessary nexus with GST proceedings. Money seized without authority must be returned or refunded. Interest and compensation for the unlawful seizure were not awarded, and other remedies remain available in law.
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