Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Extended limitation was unavailable because the disputes arose from interpretational issues, the contracts were public projects reflected in the records, and there was no cogent material showing suppression or intent to evade; demands beyond the normal period were therefore time-barred. Works contract exemption was allowed for construction of the FCI food grain godown and the Integrated Farmers' Market Complex, as both were public infrastructure projects falling within the relevant exemption entries and not shown to be predominantly commercial. The mobilization advance demand failed because it was a recoverable, interest-bearing contractual accommodation and was also time-barred. Statutory trade licence fees were treated as a regulatory levy, not taxable consideration, and the penalty for suppression was set aside. The appeal succeeded in full.
Extended limitation was unavailable because the disputes arose from interpretational issues, the contracts were public projects reflected in the records, and there was no cogent material showing suppression or intent to evade; demands beyond the normal period were therefore time-barred. Works contract exemption was allowed for construction of the FCI food grain godown and the Integrated Farmers' Market Complex, as both were public infrastructure projects falling within the relevant exemption entries and not shown to be predominantly commercial. The mobilization advance demand failed because it was a recoverable, interest-bearing contractual accommodation and was also time-barred. Statutory trade licence fees were treated as a regulatory levy, not taxable consideration, and the penalty for suppression was set aside. The appeal succeeded in full.
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