Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
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...
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Government grants-in-aid do not constitute consideration for Business Exhibition Service where agreements impose only utilisation and accounting conditions, without an obligation to provide services, invoices, or quid pro quo. As reimbursement of specified expenditure, they fall outside taxable value, which is confined to amounts charged for taxable services; the related demand was set aside. Extended limitation cannot apply where grants and expenditure were recorded, the taxpayer paid tax on other services, and a bona fide belief of non-taxability negated suppression with intent to evade. Reverse-charge demands were likewise time-barred because recorded liabilities were revenue neutral through available Cenvat credit.
Government grants-in-aid do not constitute consideration for Business Exhibition Service where agreements impose only utilisation and accounting conditions, without an obligation to provide services, invoices, or quid pro quo. As reimbursement of specified expenditure, they fall outside taxable value, which is confined to amounts charged for taxable services; the related demand was set aside. Extended limitation cannot apply where grants and expenditure were recorded, the taxpayer paid tax on other services, and a bona fide belief of non-taxability negated suppression with intent to evade. Reverse-charge demands were likewise time-barred because recorded liabilities were revenue neutral through available Cenvat credit.
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