Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
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