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    August 12, 2026   Case LawsIncome Tax
    Identity-theft defences do not bar reassessment, but Revenue must prove disputed transactions through primary evidence during proceedings.
    August 12, 2026   Case LawsIncome Tax
    Discounted Cash Flow valuation for newly incorporated companies was accepted despite later notification under the prescribed valuation rule.
    August 12, 2026   Case LawsIncome Tax
    Internal CUP method upheld for project-office transactions where contract risks, rewards and revenue were fully attributed to India.
    August 12, 2026   Case LawsIncome Tax
    Revisional relief for double taxation requires merits review where the same income is assessed in two different years.
    August 12, 2026   Case LawsIncome Tax
    Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
    August 12, 2026   Case LawsIncome Tax
    MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
    August 12, 2026   Case LawsIncome Tax
    CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.
    August 12, 2026   Case LawsIncome Tax
    TDS non-deduction under binding interim directions does not make an employer-bank an assessee in default.
    August 12, 2026   Case LawsIncome Tax
    Reassessment based on search and independent enquiry sustained, while unverifiable purchases were limited to the estimated profit element.
    August 12, 2026   Case LawsIncome Tax
    Reasonable cause for cash land-transaction receipts and repayments supported deletion of penalties for statutory cash-payment breaches.
    August 12, 2026   Case LawsIncome Tax
    Specific misreporting charge under section 270A is mandatory; failure to identify the statutory limb invalidates enhanced penalty.
    August 12, 2026   Case LawsIncome Tax
    Assessment quashing extinguishes linked cash-loan penalty, while limitation runs from the Assessing Officer's recorded initiation.
    August 12, 2026   Case LawsIncome Tax
    Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
    August 12, 2026   Case LawsIncome Tax
    Section 153C jurisdiction requires year-specific satisfaction and seized material; unabated assessments cannot sustain additions without incriminating...
    August 12, 2026   Case LawsIncome Tax
    Assessment against a deceased taxpayer is void from inception despite the legal heir pursuing appellate proceedings.
    August 12, 2026   Case LawsCustoms
    Steamer-agent liability for manifested cargo deficiency applies when the agent files and verifies the Import General Manifest, supporting penalties.
    August 12, 2026   Case LawsCustoms
    Statutory provisional release discretion prevails over executive instructions, with revenue safeguarded through duty payment and bond conditions.
    August 12, 2026   Case LawsCustoms
    DFIA classification of Vital Wheat Gluten as wheat flour defeated customs seizure based on unsupported exemption ineligibility allegations.
    August 12, 2026   Case LawsCustoms
    Automotive ECU classification follows distinct functions, requiring Revenue evidence before reclassifying control units as motor-vehicle parts.
    August 12, 2026   Case LawsCustoms
    Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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    August 12, 2026   Case Laws Income Tax
    Identity-theft defences do not bar reassessment, but Revenue must prove disputed transactions through primary evidence during proceedings.
    August 12, 2026   Case Laws Income Tax
    Discounted Cash Flow valuation for newly incorporated companies was accepted despite later notification under the prescribed valuation rule.
    August 12, 2026   Case Laws Income Tax
    Internal CUP method upheld for project-office transactions where contract risks, rewards and revenue were fully attributed to India.
    August 12, 2026   Case Laws Income Tax
    Revisional relief for double taxation requires merits review where the same income is assessed in two different years.
    August 12, 2026   Case Laws Income Tax
    Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse material.
    August 12, 2026   Case Laws Income Tax
    MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory computation rules.
    August 12, 2026   Case Laws Income Tax
    CSR donation deductions and treaty-limited dividend tax support relief for eligible contributions and UK shareholder distributions.
    August 12, 2026   Case Laws Income Tax
    TDS non-deduction under binding interim directions does not make an employer-bank an assessee in default.
    August 12, 2026   Case Laws Income Tax
    Reassessment based on search and independent enquiry sustained, while unverifiable purchases were limited to the estimated profit element.
    August 12, 2026   Case Laws Income Tax
    Reasonable cause for cash land-transaction receipts and repayments supported deletion of penalties for statutory cash-payment breaches.
    August 12, 2026   Case Laws Income Tax
    Specific misreporting charge under section 270A is mandatory; failure to identify the statutory limb invalidates enhanced penalty.
    August 12, 2026   Case Laws Income Tax
    Assessment quashing extinguishes linked cash-loan penalty, while limitation runs from the Assessing Officer's recorded initiation.
    August 12, 2026   Case Laws Income Tax
    Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequential proceedings.
    August 12, 2026   Case Laws Income Tax
    Section 153C jurisdiction requires year-specific satisfaction and seized material; unabated assessments cannot sustain additions without incriminating evidence.
    August 12, 2026   Case Laws Income Tax
    Assessment against a deceased taxpayer is void from inception despite the legal heir pursuing appellate proceedings.
    August 12, 2026   Case Laws Customs
    Steamer-agent liability for manifested cargo deficiency applies when the agent files and verifies the Import General Manifest, supporting penalties.
    August 12, 2026   Case Laws Customs
    Statutory provisional release discretion prevails over executive instructions, with revenue safeguarded through duty payment and bond conditions.
    August 12, 2026   Case Laws Customs
    DFIA classification of Vital Wheat Gluten as wheat flour defeated customs seizure based on unsupported exemption ineligibility allegations.
    August 12, 2026   Case Laws Customs
    Automotive ECU classification follows distinct functions, requiring Revenue evidence before reclassifying control units as motor-vehicle parts.
    August 12, 2026   Case Laws Customs
    Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguards.

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      Home› Highlights › GST › 2025 › February, 2025 › This
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      GST

      ANP demanded settlement fees from appellant following breach of...

      Oil Company's $80M Payment for Production Sharing Contract Breach Ruled as Damages, Not Service Consideration

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      GSTFebruary 1, 2025Case LawsAAAR
      ANP demanded settlement fees from appellant following breach of Production Sharing Contract (PSC). The AAAR determined that USD 80,000,000 payment constituted liquidated damages for PSC breach, not consideration for services. The payment was made to compensate losses under clause 4.5(a)(iii), with no evidence of agreement for ANP to perform, refrain from, or tolerate specific acts in exchange. Following established principles on liquidated damages, such payments represent mere flow of money without constituting consideration for supply. The AAAR overturned previous ruling which incorrectly characterized payment as service-related. Appellant not liable for GST on settlement fees as payment qualified as damages rather than consideration for supply under GST framework.
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