Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
GST interest on self-assessed return liabilities is discharged only when the Electronic Cash Ledger is debited towards the identified liability; a sufficient unappropriated cash balance does not stop interest until belated GSTR-3B filing. The later Rule 88B(1) proviso excluding amounts credited by the due date and continuously retained in that ledger operates prospectively, not for earlier periods. Notice proceedings remain valid where the taxpayer received the demand basis and computation, gave detailed replies, and established no actual prejudice. Denial of a requested personal hearing breached section 75(4), but did not require remand where the record was complete, the remaining issue was legal, and no lost substantive opportunity was identified. Interest demands were sustained, subject to reconciliation to prevent double recovery; substantive refund claims failed.
GST interest on self-assessed return liabilities is discharged only when the Electronic Cash Ledger is debited towards the identified liability; a sufficient unappropriated cash balance does not stop interest until belated GSTR-3B filing. The later Rule 88B(1) proviso excluding amounts credited by the due date and continuously retained in that ledger operates prospectively, not for earlier periods. Notice proceedings remain valid where the taxpayer received the demand basis and computation, gave detailed replies, and established no actual prejudice. Denial of a requested personal hearing breached section 75(4), but did not require remand where the record was complete, the remaining issue was legal, and no lost substantive opportunity was identified. Interest demands were sustained, subject to reconciliation to prevent double recovery; substantive refund claims failed.
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