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...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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Disallowance u/s 54F - Investment of Sale consideration for claiming exemption on LTCG - Advance was given for purchase of new residential property but the transaction was not materialized due to litigation - purchase of new residential property thereafter after getting refund of advance - failure to deposit into the capital gain account with the authorized banks - Since the assessee has fulfilled the substantive condition of Section 54F(1) of the Act by way of utilizing the sale consideration from sale of the capital asset (other than residential house) within two years of sale of original capital asset, assessee is eligible for deduction u/s 54F(1) - AT
Disallowance u/s 54F - Investment of Sale consideration for claiming exemption on LTCG - Advance was given for purchase of new residential property but the transaction was not materialized due to litigation - purchase of new residential property thereafter after getting refund of advance - failure to deposit into the capital gain account with the authorized banks - Since the assessee has fulfilled the substantive condition of Section 54F(1) of the Act by way of utilizing the sale consideration from sale of the capital asset (other than residential house) within two years of sale of original capital asset, assessee is eligible for deduction u/s 54F(1) - AT
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