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    October 8, 2026   Case Laws GST
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    Offshore supply receipts remain outside Indian taxation where CIF title passes abroad and contracts are genuinely separate.
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October 8, 2026   Case Laws GST
Electronic GST authentication validates portal-issued demand notices, while portal upload starts limitation and RFN can replace DIN.
October 8, 2026   Case Laws GST
Assessment of unregistered persons must precede GST recovery proceedings, leaving educational institution exemption claims open for determination.
October 8, 2026   Case Laws Customs
Revised customs prosecution thresholds can govern pending gold-smuggling complaints, requiring reconsideration of withdrawal despite prior prosecution sanction.
October 8, 2026   Case Laws GST
Leasehold rights assignments in industrial plots remain outside GST where treated as benefits arising from immovable property.
October 8, 2026   Case Laws GST
Pre-deposit timing turns on final acknowledgement, allowing a timely defect cure before appeal registration and merits consideration.
October 8, 2026   Case Laws FEMA
Proportionality review restricts reduction of FERA penalties unless the sanction is grossly excessive, unduly harsh, or conscience-shocking.
October 8, 2026   Case Laws Income Tax
Offshore supply receipts remain outside Indian taxation where CIF title passes abroad and contracts are genuinely separate.
October 8, 2026   Case Laws Income Tax
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verification.
October 8, 2026   Case Laws Income Tax
Business set-up versus commencement determines deductibility, while appellate findings require consideration of contemporaneous operational evidence.
October 8, 2026   Case Laws Income Tax
Mandatory GST credit reversal on unsold completed units becomes deductible project cost when final allocation crystallises.
October 8, 2026   Case Laws Income Tax
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore supplies.
October 8, 2026   Case Laws Income Tax
Electronic receipt of DRP directions triggers the final-assessment deadline, rendering delayed faceless assessments time-barred and invalid.
October 8, 2026   Case Laws Income Tax
Gifted share holding periods include prior ownership, but indexation begins only when the donee's deemed cost is taxed.
October 8, 2026   Case Laws Income Tax
National Highways acquisition compensation remains income-tax exempt, while delayed-payment interest is taxable as income from other sources.
October 8, 2026   Case Laws Income Tax
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and comparables.
October 8, 2026   Case Laws Customs
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appellate remedy.
October 8, 2026   Case Laws Customs
Customs detention charges cannot be imposed after clearance, requiring release of imported goods and preserving inter-party claims.
October 8, 2026   Case Laws GST
Premature GST summons challenges fail where summons merely seek information and no coercive recovery or arrest threat is evidenced.
October 8, 2026   Case Laws GST
GST appellate hearing rights protect appeals from dismissal over limitation, authority and interest-only pre-deposit objections.
October 8, 2026   Case Laws GST
Input tax credit mismatch requires documentary verification; non-appearance alone cannot end a GST appeal without merits review.

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Home › Highlights › Income Tax › 2023 › August, 2023 › This
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Income Tax

Income taxable in India - Fixed place PE in India - project...

Indian Income Tax: Offshore Supply Profits Not Attributable to Project Office Lacking Permanent Establishment Status Under BTIL.

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Income Tax August 22, 2023 Case Laws AT
Income taxable in India - Fixed place PE in India - project office in India - none of the conditions of fixed place PE stand satisfied - the attribution of profit qua the receipts from offshore supplies to the alleged fixed place PE in the form of BTIL is unsustainable as, in our view, BTIL cannot be construed as PE of the assessee in India. - AT
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