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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Departmental GST appeals involving disputed tax below the prescribed monetary limit require the Revenue to specifically plead and establish a recognised exception to the litigation-control policy. The threshold is calculated on aggregate disputed tax, excluding interest and penalty. Mere Commissioner authorisation does not establish the residual exception; the record must show a case-specific exercise of that power and its supporting basis. Where no applicable exception is proved, the appeal is not maintainable, may be dismissed at the threshold, and the underlying tax merits remain unexamined.
Departmental GST appeals involving disputed tax below the prescribed monetary limit require the Revenue to specifically plead and establish a recognised exception to the litigation-control policy. The threshold is calculated on aggregate disputed tax, excluding interest and penalty. Mere Commissioner authorisation does not establish the residual exception; the record must show a case-specific exercise of that power and its supporting basis. Where no applicable exception is proved, the appeal is not maintainable, may be dismissed at the threshold, and the underlying tax merits remain unexamined.
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