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 Decision: Infrastructure Project Tax Deduction Dispute The ITAT partially allowed the revenue's appeal, addressing multiple taxation issues. The Tribunal upheld deductions for interest income from fixed deposits directly linked to infrastructure project financing, rejecting revenue's challenge. The Tribunal recognized the business expediency of interest-free advances to a subsidiary for project development, dismissing proportionate interest expense disallowance. Concession fee was deemed allowable on accrual basis, consistent with prior rulings. However, guarantee commission income was disallowed under section 80IA, being considered unrelated to core airport infrastructure operations. The Tribunal directed the Assessing Officer to verify specific quantum of expenditures and make appropriate adjustments, essentially providing a nuanced resolution balancing taxpayer's claims and statutory interpretations.
ITAT Decision: Infrastructure Project Tax Deduction Dispute The ITAT partially allowed the revenue's appeal, addressing multiple taxation issues. The Tribunal upheld deductions for interest income from fixed deposits directly linked to infrastructure project financing, rejecting revenue's challenge. The Tribunal recognized the business expediency of interest-free advances to a subsidiary for project development, dismissing proportionate interest expense disallowance. Concession fee was deemed allowable on accrual basis, consistent with prior rulings. However, guarantee commission income was disallowed under section 80IA, being considered unrelated to core airport infrastructure operations. The Tribunal directed the Assessing Officer to verify specific quantum of expenditures and make appropriate adjustments, essentially providing a nuanced resolution balancing taxpayer's claims and statutory interpretations.
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