Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
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...
Input tax credit is a conditional statutory entitlement requiring cumulative compliance, including actual tax payment by the supplier. Recipient exposure to supplier default is addressed through reversal and subsequent re-availment of credit, with the claimant bearing the burden of proving eligibility. Fraud-based proceedings require prima facie material supporting allegations of fraud, wilful misstatement or suppression; detailed allegations of fake invoices, bogus supplies and no movement of goods require merits examination. Pre-notice intimation is enabling rather than mandatory, and investigation and adjudication by the proper officer do not alone establish bias. Merits disputes should ordinarily proceed through the statutory appellate remedy.
Input tax credit is a conditional statutory entitlement requiring cumulative compliance, including actual tax payment by the supplier. Recipient exposure to supplier default is addressed through reversal and subsequent re-availment of credit, with the claimant bearing the burden of proving eligibility. Fraud-based proceedings require prima facie material supporting allegations of fraud, wilful misstatement or suppression; detailed allegations of fake invoices, bogus supplies and no movement of goods require merits examination. Pre-notice intimation is enabling rather than mandatory, and investigation and adjudication by the proper officer do not alone establish bias. Merits disputes should ordinarily proceed through the statutory appellate remedy.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
