Fair-rent assessment requires consideration of lease terms, valuation principles and prevailing market rent; the certificate was quashed for fresh rev...
Document Identification Number compliance is satisfied when electronically communicated orders are promptly authenticated through a correctly identifi...
Industrial shrimp-feed machinery classification follows its commercial function, placing integrated production plants under the specific industrial fo...
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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