Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed.
Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed.
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