Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
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