Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
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