Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Income deemed to accrue or arise in India - addition on account of LTCG to be taxed u/s 112 - Scope of holding Tax Residency Certificate of Mauritius (TRC) - The Tribunal allowed the appeal, holding that investments made prior to April 1, 2017, are grandfathered under the India-Mauritius DTAA and not subject to capital gains taxation in India. The Tribunal followed the principles laid out in the case of Bid Services Division (Mauritius) Ltd. vs. Authority for Advance Rulings and other relevant CBDT circulars and press releases, confirming that the assessee is entitled to the DTAA benefits.
Income deemed to accrue or arise in India - addition on account of LTCG to be taxed u/s 112 - Scope of holding Tax Residency Certificate of Mauritius (TRC) - The Tribunal allowed the appeal, holding that investments made prior to April 1, 2017, are grandfathered under the India-Mauritius DTAA and not subject to capital gains taxation in India. The Tribunal followed the principles laid out in the case of Bid Services Division (Mauritius) Ltd. vs. Authority for Advance Rulings and other relevant CBDT circulars and press releases, confirming that the assessee is entitled to the DTAA benefits.
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