Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Characterization of arbitral award compensation as business income under India-Japan tax treaty. Principal portion arising from contractual obligation constitutes business income, not taxable in India due to absence of permanent establishment. Interest on compensation partakes character of business receipts, not separable as income from other sources. Entire compensation construed as business income, not taxable in India under Article 7 of tax treaty. Double addition of interest income offered in return to be deleted by Assessing Officer. Penalty proceedings unsustainable due to deletion of additions. Appellate Tribunal's decision on taxability, double deduction, and penalty.
Characterization of arbitral award compensation as business income under India-Japan tax treaty. Principal portion arising from contractual obligation constitutes business income, not taxable in India due to absence of permanent establishment. Interest on compensation partakes character of business receipts, not separable as income from other sources. Entire compensation construed as business income, not taxable in India under Article 7 of tax treaty. Double addition of interest income offered in return to be deleted by Assessing Officer. Penalty proceedings unsustainable due to deletion of additions. Appellate Tribunal's decision on taxability, double deduction, and penalty.
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