Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Maintainability of appeal - low tax effect - Penalty - Since the levy of penalty by no means could be construed as an addition within the meaning of Para 10(e) of the aforesaid circular, therefore, we do not find any merit in the claim raised by the revenue that the aforementioned exception carved out in the CBDT Circular No. 3/2018 (supra) would also take within its sweep penalty imposed by the A.O. under Sec. 271(1)(c) of the Act in respect of an addition of bogus purchases on the basis of an information received from Sales Tax Authorities i.e. an external agency. - AT
Maintainability of appeal - low tax effect - Penalty - Since the levy of penalty by no means could be construed as an addition within the meaning of Para 10(e) of the aforesaid circular, therefore, we do not find any merit in the claim raised by the revenue that the aforementioned exception carved out in the CBDT Circular No. 3/2018 (supra) would also take within its sweep penalty imposed by the A.O. under Sec. 271(1)(c) of the Act in respect of an addition of bogus purchases on the basis of an information received from Sales Tax Authorities i.e. an external agency. - AT
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