Draft assessment procedure cannot create enforceable tax demand where no final assessment exists or international transaction variation is proposed.

Finality of appellate findings bars revision, while unsupported allegations of undisclosed tanker income cannot sustain an addition.

Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...

Safe harbour for unquoted share valuation treats issue price within the permitted Rule 11UA variation as fair market value.

Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...

Undisclosed income requirement limits search penalty where surrendered land advances are merely uncorroborated applications of funds.

Erroneous and prejudicial assessments permit revision where deeming provisions, special tax rates, and penalty proceedings were overlooked.

Protective additions for seized jewellery require independent evidence once ownership is substantively assessed in another taxpayer's hands.

Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...

Approved resolution plans bind tax authorities and extinguish pre-approval tax appeals where plan terms require withdrawal of proceedings.

Penalty immunity under Vivad Se Vishwas excludes independent tax-audit defaults; futures and options turnover requires factual verification.

Eligible company incorporation timing controls capital-gains exemption; later commencement of manufacturing cannot cure an earlier incorporation date.

Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...

Sufficient cause for customs appeal delay requires bona fide diligence throughout; prolonged unexplained inaction defeats condonation.

Fire-damaged vehicles treated as scrap cannot trigger import licensing confiscation, while vessel berthing alone is not unloading.

Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...

Delayed customs refund interest starts after the refund-application period, with an enhanced rate for prolonged Revenue inaction.

Special Additional Duty refund limitation cannot curtail substantive refund rights through subordinate legislation without statutory authority.

Toy parts classification permits concessional customs duty treatment where imported components lack the essential character of complete ride-on toys.

Customs transaction value rejection requires Rule 12 procedure despite importer consent to reassessment of imported scrap values.