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...
GST input tax credit may be assessed through aggregate reconciliation of IGST, CGST and SGST credits, including IGST paid on imports. Surplus IGST credit remaining after discharge of IGST liability can be used towards CGST and SGST liabilities, so an apparent CGST or SGST credit shortfall may not establish excess credit availment or tax short payment. GST adjudication must also afford a personal hearing, address taxpayer contentions and evidence, and give reasoned findings; orders issued without these safeguards risk breach of natural justice and non-application of mind.
GST input tax credit may be assessed through aggregate reconciliation of IGST, CGST and SGST credits, including IGST paid on imports. Surplus IGST credit remaining after discharge of IGST liability can be used towards CGST and SGST liabilities, so an apparent CGST or SGST credit shortfall may not establish excess credit availment or tax short payment. GST adjudication must also afford a personal hearing, address taxpayer contentions and evidence, and give reasoned findings; orders issued without these safeguards risk breach of natural justice and non-application of mind.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
