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...
Head office services supplied to separately registered branches or depots constitute supplies between distinct persons even without consideration. Where no invoices are issued for those services, CBIC clarifications and Rule 28 require their value to be treated as nil; common expenditure cannot instead be proportionately allocated to create taxable value. Extended limitation under Section 74 requires facts establishing fraud, wilful misstatement or suppression with intent to evade tax, rather than mechanical allegations. Recorded expenditure and recipient eligibility for input tax credit may demonstrate revenue neutrality and, without more, do not establish those conditions.
Head office services supplied to separately registered branches or depots constitute supplies between distinct persons even without consideration. Where no invoices are issued for those services, CBIC clarifications and Rule 28 require their value to be treated as nil; common expenditure cannot instead be proportionately allocated to create taxable value. Extended limitation under Section 74 requires facts establishing fraud, wilful misstatement or suppression with intent to evade tax, rather than mechanical allegations. Recorded expenditure and recipient eligibility for input tax credit may demonstrate revenue neutrality and, without more, do not establish those conditions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
