Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
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