Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
HC allowed the writ petition challenging Commissioner's order under Section 264. Prior amendment of Return of Income was not mandatory before filing revision application. Commissioner failed to consider DTAA provisions and "make available" clause for determining royalty payments. Following Vijay Gupta and Interglobe Enterprises precedents, Court held that taxpayers can rectify earlier mistaken positions through Section 264, even for suo moto disallowances made under incorrect interpretation. Tax liability exists only for income chargeable under the Act. Commissioner directed to reconsider revision application examining DTAA implications and royalty characterization afresh, particularly the "make available" condition.
HC allowed the writ petition challenging Commissioner's order under Section 264. Prior amendment of Return of Income was not mandatory before filing revision application. Commissioner failed to consider DTAA provisions and "make available" clause for determining royalty payments. Following Vijay Gupta and Interglobe Enterprises precedents, Court held that taxpayers can rectify earlier mistaken positions through Section 264, even for suo moto disallowances made under incorrect interpretation. Tax liability exists only for income chargeable under the Act. Commissioner directed to reconsider revision application examining DTAA implications and royalty characterization afresh, particularly the "make available" condition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
