COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
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The ITAT held that identical issues arose in the assessee's own case for AY 2019-20 which was decided in favour of the assessee, thus there is no justification in attributing the profit on offshore sale of equipment. Regarding receipt from Glidepath, New Zealand, the ITAT found no artificial splitting of contracts and relied on the Supreme Court's decision in Morgan Stanley to hold that the receipt cannot be subjected to tax. For receipts from KITCOL, TTD and CIAL, the matter was restored to the AO to examine double taxation after the assessee furnishes evidence of offering the receipts in earlier years.
The ITAT held that identical issues arose in the assessee's own case for AY 2019-20 which was decided in favour of the assessee, thus there is no justification in attributing the profit on offshore sale of equipment. Regarding receipt from Glidepath, New Zealand, the ITAT found no artificial splitting of contracts and relied on the Supreme Court's decision in Morgan Stanley to hold that the receipt cannot be subjected to tax. For receipts from KITCOL, TTD and CIAL, the matter was restored to the AO to examine double taxation after the assessee furnishes evidence of offering the receipts in earlier years.
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