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...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
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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