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...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Separate offshore-supply, domestic-supply and domestic-service contracts in a transmission project need not be treated as artificial splitting merely because project safeguards, acceptance testing and performance obligations apply. Where goods are supplied on CIF terms and title passes outside India, offshore-supply receipts are not taxable in India. An Indian associate conducting an independent business does not create a fixed-place or dependent-agent permanent establishment without legal, economic or other dependence. The presumptive computation provision for turnkey power projects does not extend to receipts from mere offshore supply under a separate contract.
Separate offshore-supply, domestic-supply and domestic-service contracts in a transmission project need not be treated as artificial splitting merely because project safeguards, acceptance testing and performance obligations apply. Where goods are supplied on CIF terms and title passes outside India, offshore-supply receipts are not taxable in India. An Indian associate conducting an independent business does not create a fixed-place or dependent-agent permanent establishment without legal, economic or other dependence. The presumptive computation provision for turnkey power projects does not extend to receipts from mere offshore supply under a separate contract.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
