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    July 22, 2026   Case LawsGST
    Input tax credit reversal verification required fresh GST demand adjudication, subject to pre-deposit and adjustment of substantiated payments.
    July 22, 2026   Case LawsCustoms
    Redemption of non-declared gold ornaments may replace absolute confiscation where baggage circumstances do not indicate organised smuggling activity.
    July 22, 2026   Case LawsCustoms
    Conditional customs exemption requires IGCR compliance from import, preventing concessional duty claims first made at ex-bonding.
    July 22, 2026   Case LawsCustoms
    Tariff classification follows inactive yeast's essential character, not its animal-feed use, excluding treatment as an animal-feed preparation.
    July 22, 2026   Case LawsGST
    Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
    July 22, 2026   Case LawsGST
    Input tax credit for bona fide purchasers cannot be denied solely for a supplier's return-filing default.
    July 22, 2026   Case LawsGST
    Inverted duty refunds cover credit accumulated from higher-rated ancillary inputs, despite equal tax rates on principal input and output.
    July 22, 2026   Case LawsGST
    Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
    July 22, 2026   Case LawsIncome Tax
    Partner capital contribution evidenced through banking records discharged cash-credit onus, requiring deletion of the unexplained-credit addition.
    July 22, 2026   Case LawsIncome Tax
    Unexplained cash-credit additions require consideration of lender-source evidence and relevant precedents before a fresh determination.
    July 22, 2026   Case LawsIncome Tax
    Foreign tax credit claims require verification, while genuine lack of awareness of electronic appeals can justify condoning delay.
    July 22, 2026   Case LawsIncome Tax
    Fees for technical services treatment of software and SaaS depends on human intervention and specialised customer-specific services.
    July 22, 2026   Case LawsIncome Tax
    Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
    July 22, 2026   Case LawsIncome Tax
    Belated tax audit reporting may be a technical breach where the report was considered during reassessment without additions.
    July 22, 2026   Case LawsIncome Tax
    Commission income in principal-agent sales is estimated on limited mark-up, while agency receipts cannot be treated as turnover.
    July 22, 2026   Case LawsIncome Tax
    Section 54 exemption covers a multi-floor home acquired as one property, while unsupported land valuation rejection requires recomputation.
    July 22, 2026   Case LawsIncome Tax
    Joint development agreements trigger capital gains on development possession, while multiple allotted flats may receive residential exemption.
    July 22, 2026   Case LawsIncome Tax
    Bona fide Form 26QB PAN errors require verification and manual TDS credit rectification; factually flawed reassessment notices fail.
    July 22, 2026   Case LawsIncome Tax
    Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
    July 22, 2026   Case LawsIncome Tax
    Unsupported cost estimation fails, while timely residential-property investment preserves section 54F relief despite procedural deposit non-compliance...
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    July 22, 2026   Case Laws GST
    Input tax credit reversal verification required fresh GST demand adjudication, subject to pre-deposit and adjustment of substantiated payments.
    July 22, 2026   Case Laws Customs
    Redemption of non-declared gold ornaments may replace absolute confiscation where baggage circumstances do not indicate organised smuggling activity.
    July 22, 2026   Case Laws Customs
    Conditional customs exemption requires IGCR compliance from import, preventing concessional duty claims first made at ex-bonding.
    July 22, 2026   Case Laws Customs
    Tariff classification follows inactive yeast's essential character, not its animal-feed use, excluding treatment as an animal-feed preparation.
    July 22, 2026   Case Laws GST
    Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter.
    July 22, 2026   Case Laws GST
    Input tax credit for bona fide purchasers cannot be denied solely for a supplier's return-filing default.
    July 22, 2026   Case Laws GST
    Inverted duty refunds cover credit accumulated from higher-rated ancillary inputs, despite equal tax rates on principal input and output.
    July 22, 2026   Case Laws GST
    Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency.
    July 22, 2026   Case Laws Income Tax
    Partner capital contribution evidenced through banking records discharged cash-credit onus, requiring deletion of the unexplained-credit addition.
    July 22, 2026   Case Laws Income Tax
    Unexplained cash-credit additions require consideration of lender-source evidence and relevant precedents before a fresh determination.
    July 22, 2026   Case Laws Income Tax
    Foreign tax credit claims require verification, while genuine lack of awareness of electronic appeals can justify condoning delay.
    July 22, 2026   Case Laws Income Tax
    Fees for technical services treatment of software and SaaS depends on human intervention and specialised customer-specific services.
    July 22, 2026   Case Laws Income Tax
    Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed income.
    July 22, 2026   Case Laws Income Tax
    Belated tax audit reporting may be a technical breach where the report was considered during reassessment without additions.
    July 22, 2026   Case Laws Income Tax
    Commission income in principal-agent sales is estimated on limited mark-up, while agency receipts cannot be treated as turnover.
    July 22, 2026   Case Laws Income Tax
    Section 54 exemption covers a multi-floor home acquired as one property, while unsupported land valuation rejection requires recomputation.
    July 22, 2026   Case Laws Income Tax
    Joint development agreements trigger capital gains on development possession, while multiple allotted flats may receive residential exemption.
    July 22, 2026   Case Laws Income Tax
    Bona fide Form 26QB PAN errors require verification and manual TDS credit rectification; factually flawed reassessment notices fail.
    July 22, 2026   Case Laws Income Tax
    Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash deposits.
    July 22, 2026   Case Laws Income Tax
    Unsupported cost estimation fails, while timely residential-property investment preserves section 54F relief despite procedural deposit non-compliance.

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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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