Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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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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