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...
ITAT quashed the reassessment proceedings initiated under s.147, finding the AO adopted a "blind approach" without proper appreciation of facts. The notice dated 31/03/2019 under s.148 and subsequent assessment order under s.143(3) read with s.147 were invalidated. The Tribunal upheld CIT(A)'s deletion of additions related to UK Film Tax Relief, noting these amounts had already been accounted for by EMIL in net realization figures. Regarding payments to Winford Production Ltd (UK), ITAT determined these were mere reimbursements of expenses for shooting arrangements and not fees for technical services under Indo-UK DTAA, as no technical knowledge was "made available" to the assessee. Consequently, no TDS obligation arose under s.195, and disallowance under s.40(a)(i) was deleted.
ITAT quashed the reassessment proceedings initiated under s.147, finding the AO adopted a "blind approach" without proper appreciation of facts. The notice dated 31/03/2019 under s.148 and subsequent assessment order under s.143(3) read with s.147 were invalidated. The Tribunal upheld CIT(A)'s deletion of additions related to UK Film Tax Relief, noting these amounts had already been accounted for by EMIL in net realization figures. Regarding payments to Winford Production Ltd (UK), ITAT determined these were mere reimbursements of expenses for shooting arrangements and not fees for technical services under Indo-UK DTAA, as no technical knowledge was "made available" to the assessee. Consequently, no TDS obligation arose under s.195, and disallowance under s.40(a)(i) was deleted.
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