Fake-invoice penalties remain available where taxpayer admissions and records establish unsupported input tax credit claims and false GST documentatio...
Works contract classification applies to permanently installed fire-protection systems, while earthwork and obsolete IGST concessions remain unavailab...
Professional fee recovery for GST refund representation succeeds where direct engagement, fee acknowledgement, and authority are established despite c...
Transfer pricing of intra-group support services requires prescribed benchmarking; unsupported nil valuation and alternate business-expense disallowan...
Revisionary jurisdiction requires an assessment to be both erroneous and prejudicial to Revenue; a possible need for further enquiry, without identifying an indispensable omitted enquiry, an untenable assessment view, and resulting prejudice, is insufficient. Employee stock-option discounts, including liability crystallising on scheme modification, constitute employee-remuneration expenditure rather than capital or share-premium shortfall. A revision cannot rely on a ground absent from the show-cause notice. MAT book-profit adjustment for exempt-income expenditure requires independent identification of book-debited expenditure and cannot mechanically adopt Rule 8D. Deemed dividend requires legal shareholder membership in the recipient concern; indirect economic interest is inadequate, and related interest disallowance needs an independent non-business-use finding. The revisionary orders were quashed.
Revisionary jurisdiction requires an assessment to be both erroneous and prejudicial to Revenue; a possible need for further enquiry, without identifying an indispensable omitted enquiry, an untenable assessment view, and resulting prejudice, is insufficient. Employee stock-option discounts, including liability crystallising on scheme modification, constitute employee-remuneration expenditure rather than capital or share-premium shortfall. A revision cannot rely on a ground absent from the show-cause notice. MAT book-profit adjustment for exempt-income expenditure requires independent identification of book-debited expenditure and cannot mechanically adopt Rule 8D. Deemed dividend requires legal shareholder membership in the recipient concern; indirect economic interest is inadequate, and related interest disallowance needs an independent non-business-use finding. The revisionary orders were quashed.
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