Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
Technical expert opinion in customs classification and exemption disputes must be meaningfully evaluated where eligibility depends on physical inspection and component-level analysis. An adjudicating authority cannot reject such opinion through its own technical perception without a reasoned technical rebuttal supported by comparable expert or scientific material. The order denying concessional customs duty for Battery Management Systems and Cell Supervisory Circuits was quashed and remanded for fresh adjudication, with liberty to obtain a counter-expert opinion. Writ jurisdiction was exercised despite an alternative appellate remedy because the specialised technical opinion had been disregarded without a reasoned technical basis.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
