Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
AAAR affirmed the appellate authority's determination and dismissed the departmental appeal, holding that input tax credit (ITC) on capital goods comprising wires, cables and electrical equipment used to connect the DISCOM power supply to the respondent's factory is admissible. The Authority found no legally tenable ground in the Revenue's challenge that such items are excluded as 'plant and machinery' under section 17(5) or that section 18(6) procedures were infringed; the Revenue's contention of subsequent transfer to the transmission utility was unsubstantiated. In light of Board clarifications treating analogous infrastructure items as eligible, the GAAR findings were upheld and the appeal by the Assistant Commissioner was rejected.
AAAR affirmed the appellate authority's determination and dismissed the departmental appeal, holding that input tax credit (ITC) on capital goods comprising wires, cables and electrical equipment used to connect the DISCOM power supply to the respondent's factory is admissible. The Authority found no legally tenable ground in the Revenue's challenge that such items are excluded as 'plant and machinery' under section 17(5) or that section 18(6) procedures were infringed; the Revenue's contention of subsequent transfer to the transmission utility was unsubstantiated. In light of Board clarifications treating analogous infrastructure items as eligible, the GAAR findings were upheld and the appeal by the Assistant Commissioner was rejected.
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