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    May 27, 2026   Case LawsIncome Tax
    Unaccounted sales and bogus purchase additions: tribunal limits taxation to profit element, rejects blanket add-ons, and allows telescoping.
    May 27, 2026   Case LawsIncome Tax
    Bogus purchase additions fail where documentary evidence is unrebutted and suspicion is not backed by independent enquiry.
    May 27, 2026   Case LawsIncome Tax
    Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
    May 27, 2026   Case LawsIncome Tax
    Defective notice format, rejection of books, and unexplained cash deposits were addressed through technical and remand-based tax rulings.
    May 27, 2026   Case LawsIncome Tax
    Employee benefit, share premium, ESOP and subsidiary loss claims turn on evidence, valuation and commercial expediency
    May 27, 2026   Case LawsIncome Tax
    Charitable trust taxed at normal slab rates where trustees had no income share and public-benefit activities were involved.
    May 27, 2026   Case LawsIncome Tax
    Revision under section 263 requires error and prejudice; claimed deductions and losses were upheld on lawful assessment and supporting records.
    May 27, 2026   Case LawsIncome Tax
    Jurisdiction transfer under section 127 rendered reassessment void ab initio when the original officer acted without authority.
    May 27, 2026   Case LawsCustoms
    Specific tariff classification for n-Hexane prevailed over motor spirit treatment, with Chapter 29 classification upheld.
    May 27, 2026   Case LawsCustoms
    Customs investigation communication cannot replace adjudication; liability must be by show cause notice and final proceedings
    May 27, 2026   Case LawsCustoms
    Customs valuation based only on NIDB data was held unsustainable, and enhanced duty payment did not bar appeal.
    May 27, 2026   Case LawsCustoms
    Steamer agent penalty and retained onboard cargo confiscation rejected for lack of mens rea and import character
    May 27, 2026   Case LawsCustoms
    Zircon sand classified as concentrate, exemption denied, duty upheld, cross-examination challenge rejected, and penalty set aside.
    May 27, 2026   Case LawsIBC
    Pre-CIRP security deposit adjustment and finality of an approved resolution plan barred reopening settled claims.
    May 27, 2026   Case LawsIBC
    Limited interference with resolution plans where claims remain disputed and contingent; recall of an implemented plan was refused.
    May 27, 2026   Case LawsIBC
    Limitation under the Insolvency Code runs from pronouncement, and delay beyond the outer condonable period cannot be excused.
    May 27, 2026   Case LawsService Tax
    Substantial question of law saves departmental appeal; Barauni terminal facility treated as independent storage and warehousing service.
    May 27, 2026   Case LawsIndian Laws
    Industrial policy electricity concession limited to new units; retrospective clarification excluded expanded existing enterprises from Clause 16(a).
    May 27, 2026   Case LawsIndian Laws
    Power of attorney complaint in cheque dishonour case upheld; no failure of justice shown, but sentence was reduced.
    May 26, 2026   CircularsCustoms
    Case briefing and file management instructions issued to ensure effective Supreme Court matter handling and ASG support.
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    May 27, 2026   Case Laws Income Tax
    Unaccounted sales and bogus purchase additions: tribunal limits taxation to profit element, rejects blanket add-ons, and allows telescoping.
    May 27, 2026   Case Laws Income Tax
    Bogus purchase additions fail where documentary evidence is unrebutted and suspicion is not backed by independent enquiry.
    May 27, 2026   Case Laws Income Tax
    Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified.
    May 27, 2026   Case Laws Income Tax
    Defective notice format, rejection of books, and unexplained cash deposits were addressed through technical and remand-based tax rulings.
    May 27, 2026   Case Laws Income Tax
    Employee benefit, share premium, ESOP and subsidiary loss claims turn on evidence, valuation and commercial expediency
    May 27, 2026   Case Laws Income Tax
    Charitable trust taxed at normal slab rates where trustees had no income share and public-benefit activities were involved.
    May 27, 2026   Case Laws Income Tax
    Revision under section 263 requires error and prejudice; claimed deductions and losses were upheld on lawful assessment and supporting records.
    May 27, 2026   Case Laws Income Tax
    Jurisdiction transfer under section 127 rendered reassessment void ab initio when the original officer acted without authority.
    May 27, 2026   Case Laws Customs
    Specific tariff classification for n-Hexane prevailed over motor spirit treatment, with Chapter 29 classification upheld.
    May 27, 2026   Case Laws Customs
    Customs investigation communication cannot replace adjudication; liability must be by show cause notice and final proceedings
    May 27, 2026   Case Laws Customs
    Customs valuation based only on NIDB data was held unsustainable, and enhanced duty payment did not bar appeal.
    May 27, 2026   Case Laws Customs
    Steamer agent penalty and retained onboard cargo confiscation rejected for lack of mens rea and import character
    May 27, 2026   Case Laws Customs
    Zircon sand classified as concentrate, exemption denied, duty upheld, cross-examination challenge rejected, and penalty set aside.
    May 27, 2026   Case Laws IBC
    Pre-CIRP security deposit adjustment and finality of an approved resolution plan barred reopening settled claims.
    May 27, 2026   Case Laws IBC
    Limited interference with resolution plans where claims remain disputed and contingent; recall of an implemented plan was refused.
    May 27, 2026   Case Laws IBC
    Limitation under the Insolvency Code runs from pronouncement, and delay beyond the outer condonable period cannot be excused.
    May 27, 2026   Case Laws Service Tax
    Substantial question of law saves departmental appeal; Barauni terminal facility treated as independent storage and warehousing service.
    May 27, 2026   Case Laws Indian Laws
    Industrial policy electricity concession limited to new units; retrospective clarification excluded expanded existing enterprises from Clause 16(a).
    May 27, 2026   Case Laws Indian Laws
    Power of attorney complaint in cheque dishonour case upheld; no failure of justice shown, but sentence was reduced.
    May 26, 2026   Circulars Customs
    Case briefing and file management instructions issued to ensure effective Supreme Court matter handling and ASG support.

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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 TaxAugust 22, 2023Case LawsAT
      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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