Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
Assessment against deceased sole proprietor requires proceedings against the legal representative, rendering prior assessment and appellate orders inv...
Residential waste collection classification under SAC 999423 defeats composite-supply exemption where facilitating goods are not transferred to the lo...
Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
HC held that the assessee was not entitled to special deduction under s.42 for the relevant assessment year. Relying on the Production Sharing Contract (PSC), HC affirmed that tax authorities are bound strictly by the contractual stipulations and cannot rely on external understandings or prior correspondence, as these are superseded by Article 32, which mandates written amendment signed by all parties. Consequently, the AO correctly denied the deduction under s.42. On reopening, HC held that the reassessment was valid, as there had been no prior scrutiny or examination of the s.42 deduction in the original assessment and hence the reopening could not be characterised as a mere change of opinion. In view of this, HC declined to interfere with the reassessment and upheld the Revenue's position.
HC held that the assessee was not entitled to special deduction under s.42 for the relevant assessment year. Relying on the Production Sharing Contract (PSC), HC affirmed that tax authorities are bound strictly by the contractual stipulations and cannot rely on external understandings or prior correspondence, as these are superseded by Article 32, which mandates written amendment signed by all parties. Consequently, the AO correctly denied the deduction under s.42. On reopening, HC held that the reassessment was valid, as there had been no prior scrutiny or examination of the s.42 deduction in the original assessment and hence the reopening could not be characterised as a mere change of opinion. In view of this, HC declined to interfere with the reassessment and upheld the Revenue's position.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
