TDS on agricultural land transfers cannot arise through enhanced PAN-based rates where the primary deduction provision is inapplicable.

Diamond grading reports do not make available technical know-how, so non-resident certification payments may fall outside withholding tax.

Goodwill from slump sales remains depreciable where newly created, while non-compete fees cannot support depreciation claims.

Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...

Documented funding sources and pending valuation reference defeat unexplained investment and stamp-duty differential additions for property purchases.

Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...

Carry-forward of losses remains available to educational trusts assessed as Associations of Persons despite absent charitable registration.

Unexercised stock option repurchase constitutes transfer of a capital asset and is taxable as long-term capital gains.

Permanent establishment taxation addresses head-office interest, arm's length guarantees, capital hedges, refund interest, and treaty tax ceilings.

Satellite transponder services are not royalty where customers receive communications without rights to use equipment or processes.

Competent authority approval after three years is jurisdictional; reassessment based on invalid sanction is void from inception.

Customs valuation and anti-dumping duty disputes must be appealed to the Supreme Court, not the High Court.

Customs Broker due diligence requires evidence of knowledge or collusion before liability for an importer's misdeclaration arises.

Misdeclaration of imported goods requires supporting evidence, while redemption fine depends on market price and profit margin determination.

Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...

Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...

Proof of software import is essential for foreign-exchange remittances, and responsible officers may incur vicarious FEMA liability.

FEMA compliance turns on valid approval, substantive escrow arrangements, officer due diligence, and residential status for repatriation duties.

Examination-related service exemption covers integral services provided to schools, defeating tax demand, extended limitation and penalties.

Agreement to tolerate an act requires a separate contract, so retained insurance premiums escape service tax.