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    October 8, 2026   Case Laws Income Tax
    Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
    October 8, 2026   Case Laws Income Tax
    Revisionary jurisdiction fails where examined, plausible exemption claims for compulsory-acquisition interest are challenged solely on taxability.
    October 8, 2026   Case Laws Income Tax
    Unverifiable Purchases: accepted sales support profit-element addition, while transaction-specific intelligence sustains reassessment jurisdiction and...
    October 8, 2026   Case Laws Income Tax
    TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
    October 8, 2026   Case Laws Income Tax
    Proportionate common-expenditure deduction protects taxable non-member receipts; cellular-tower terrace rent is house-property income with statutory d...
    October 8, 2026   Case Laws Income Tax
    Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
    October 8, 2026   Case Laws Income Tax
    Post-search reassessment: Statutorily deemed income-escape information requires section 148 proceedings instead of continued scrutiny assessment under...
    October 8, 2026   Case Laws Income Tax
    Cash credit verification deletes unsupported unsecured-loan addition but requires fresh examination of flat-sale receipts and purchaser deposits.
    October 8, 2026   Case Laws Income Tax
    Net taxable income after charitable-exemption denial requires verification of admissible expenditure rather than taxation of gross receipts.
    October 8, 2026   Case Laws Income Tax
    Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
    October 8, 2026   Case Laws Income Tax
    Agricultural land compensation outside municipal limits avoids capital-gains tax; structure compensation permits cost-of-acquisition deduction in comp...
    October 8, 2026   Case Laws Income Tax
    Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
    October 8, 2026   Case Laws Benami Property
    Benami land acquisition: cumulative evidence of limited means, payment source and purchaser statements supported provisional attachment.
    October 8, 2026   Case Laws Customs
    Interest on IGST on imported goods is unsustainable without a statutory charging provision for interest recovery.
    October 8, 2026   Case Laws Customs
    Customs revision under Section 129DD permits remand without separate enhancement notice where material evidence requires fresh adjudication.
    October 8, 2026   Case Laws Customs
    Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
    October 8, 2026   Case Laws Customs
    Unchallenged redemption orders bar indirect challenges to customs duty conditions, while detention charges require proof of statutory infirmity.
    October 8, 2026   Case Laws Customs
    Consignment-specific customs classification bars unsupported reliance on later test reports and protects scrap imports from revaluation and penalties.
    October 8, 2026   Case Laws Customs
    Duplicated customs-duty refunds cannot depend on unavailable ICEGATE challans; delayed refunds processed under statutory procedure attract interest.
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    Election to realise security outside liquidation must be clearly and timely communicated, or secured assets remain in the liquidation estate.
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October 8, 2026   Case Laws Income Tax
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or ownership.
October 8, 2026   Case Laws Income Tax
Revisionary jurisdiction fails where examined, plausible exemption claims for compulsory-acquisition interest are challenged solely on taxability.
October 8, 2026   Case Laws Income Tax
Unverifiable Purchases: accepted sales support profit-element addition, while transaction-specific intelligence sustains reassessment jurisdiction and limits remand.
October 8, 2026   Case Laws Income Tax
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins fall within range.
October 8, 2026   Case Laws Income Tax
Proportionate common-expenditure deduction protects taxable non-member receipts; cellular-tower terrace rent is house-property income with statutory deductions.
October 8, 2026   Case Laws Income Tax
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars penalties.
October 8, 2026   Case Laws Income Tax
Post-search reassessment: Statutorily deemed income-escape information requires section 148 proceedings instead of continued scrutiny assessment under the new framework.
October 8, 2026   Case Laws Income Tax
Cash credit verification deletes unsupported unsecured-loan addition but requires fresh examination of flat-sale receipts and purchaser deposits.
October 8, 2026   Case Laws Income Tax
Net taxable income after charitable-exemption denial requires verification of admissible expenditure rather than taxation of gross receipts.
October 8, 2026   Case Laws Income Tax
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barred.
October 8, 2026   Case Laws Income Tax
Agricultural land compensation outside municipal limits avoids capital-gains tax; structure compensation permits cost-of-acquisition deduction in compulsory acquisitions.
October 8, 2026   Case Laws Income Tax
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursements.
October 8, 2026   Case Laws Benami Property
Benami land acquisition: cumulative evidence of limited means, payment source and purchaser statements supported provisional attachment.
October 8, 2026   Case Laws Customs
Interest on IGST on imported goods is unsustainable without a statutory charging provision for interest recovery.
October 8, 2026   Case Laws Customs
Customs revision under Section 129DD permits remand without separate enhancement notice where material evidence requires fresh adjudication.
October 8, 2026   Case Laws Customs
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document penalty failed.
October 8, 2026   Case Laws Customs
Unchallenged redemption orders bar indirect challenges to customs duty conditions, while detention charges require proof of statutory infirmity.
October 8, 2026   Case Laws Customs
Consignment-specific customs classification bars unsupported reliance on later test reports and protects scrap imports from revaluation and penalties.
October 8, 2026   Case Laws Customs
Duplicated customs-duty refunds cannot depend on unavailable ICEGATE challans; delayed refunds processed under statutory procedure attract interest.
October 8, 2026   Case Laws IBC
Election to realise security outside liquidation must be clearly and timely communicated, or secured assets remain in the liquidation estate.

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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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Acts Income Tax
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