Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Scope of rectification u/s 154 - Allowing the rectification application CIT(A) admitted the claim of expenditure - The ITAT concluded that the question of comparables in the appellant's business line involved subjective adjudication and detailed inquiries, which were beyond the scope of rectification proceedings under Section 154. Citing the precedent set by the Supreme Court, the ITAT emphasized that rectification is meant for correcting apparent mistakes on record, not for conducting detailed investigations. - The Revenue's appeal was allowed on the grounds that the appellant's rectification was not maintainable, as the Assessing Officer's findings had not been reversed by the NFAC.
Scope of rectification u/s 154 - Allowing the rectification application CIT(A) admitted the claim of expenditure - The ITAT concluded that the question of comparables in the appellant's business line involved subjective adjudication and detailed inquiries, which were beyond the scope of rectification proceedings under Section 154. Citing the precedent set by the Supreme Court, the ITAT emphasized that rectification is meant for correcting apparent mistakes on record, not for conducting detailed investigations. - The Revenue's appeal was allowed on the grounds that the appellant's rectification was not maintainable, as the Assessing Officer's findings had not been reversed by the NFAC.
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