Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
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On identical facts, the ITAT followed its earlier order and held that the Revenue had failed to establish any permanent establishment in India for the assessee in relation to offshore supply under the ONGC contract. As a result, the offshore supply receipts could not be taxed on a presumptive basis under section 44BB, and the addition was deleted. The Tribunal also noted that the DRP had found the facts unchanged from earlier years; interest and penalty grounds were treated as consequential.
On identical facts, the ITAT followed its earlier order and held that the Revenue had failed to establish any permanent establishment in India for the assessee in relation to offshore supply under the ONGC contract. As a result, the offshore supply receipts could not be taxed on a presumptive basis under section 44BB, and the addition was deleted. The Tribunal also noted that the DRP had found the facts unchanged from earlier years; interest and penalty grounds were treated as consequential.
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