Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Voyage charter arrangements were held to be contracts of carriage, not supply of tangible goods for use, because the vessel owners retained possession, command, navigation and effective control, while the recipient had no independent right to deploy or exploit the vessel. Bills of lading, freight-based invoicing and charter clauses on demurrage or port charges were treated as incidents of transport, and voyages from foreign ports to India were also noted as non-taxable for the relevant period. The extended period failed because the dispute was interpretational, the transactions were recorded in books and departmental audits had already covered them; penalties were therefore unsustainable.
Voyage charter arrangements were held to be contracts of carriage, not supply of tangible goods for use, because the vessel owners retained possession, command, navigation and effective control, while the recipient had no independent right to deploy or exploit the vessel. Bills of lading, freight-based invoicing and charter clauses on demurrage or port charges were treated as incidents of transport, and voyages from foreign ports to India were also noted as non-taxable for the relevant period. The extended period failed because the dispute was interpretational, the transactions were recorded in books and departmental audits had already covered them; penalties were therefore unsustainable.
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