Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
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Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.
Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.
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