Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Receipts from feeder vessels and slot-hire arrangements were held to have a direct and integral nexus with the assessee's shipping business in international traffic, so they fell within Article 8 of the India-Germany DTAA and could not be separately taxed under section 44B; the addition on those receipts was deleted. The Tribunal did not decide the short TDS credit claim on merits and remitted it to the Assessing Officer for factual verification against the income offered and corresponding tax deducted, with a fresh decision after hearing the assessee.
Receipts from feeder vessels and slot-hire arrangements were held to have a direct and integral nexus with the assessee's shipping business in international traffic, so they fell within Article 8 of the India-Germany DTAA and could not be separately taxed under section 44B; the addition on those receipts was deleted. The Tribunal did not decide the short TDS credit claim on merits and remitted it to the Assessing Officer for factual verification against the income offered and corresponding tax deducted, with a fresh decision after hearing the assessee.
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