Revisional jurisdiction over export quota premium deductions requires both error and Revenue prejudice; a permissible assessment view cannot be displa...
Final benami adjudication bars contradictory tax-evasion prosecution where settlement findings confirm full disclosure and cooperation without conceal...
Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
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Operational expenditure incurred to run an already deployed, revenue-generating telecom network retains its revenue character even when recorded as capital work-in-progress; book entries do not conclusively determine tax deductibility. Absent identification of an asset created or a nexus with acquisition or construction, deferral until quality-of-service targets are met does not make recurring operating costs capital. Payments to non-resident telecom operators for connectivity, carriage, termination, bandwidth and maintenance are not royalty or technical-service fees where the payer obtains no right to use equipment or process and receives no technical capability. Without Indian taxability or a permanent establishment, no withholding obligation arises.
Operational expenditure incurred to run an already deployed, revenue-generating telecom network retains its revenue character even when recorded as capital work-in-progress; book entries do not conclusively determine tax deductibility. Absent identification of an asset created or a nexus with acquisition or construction, deferral until quality-of-service targets are met does not make recurring operating costs capital. Payments to non-resident telecom operators for connectivity, carriage, termination, bandwidth and maintenance are not royalty or technical-service fees where the payer obtains no right to use equipment or process and receives no technical capability. Without Indian taxability or a permanent establishment, no withholding obligation arises.
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