Revenue authority mandates using scheme-specific reversal procedures, not revising original entries, for instrument-based trade/customs benefits effec...
Transaction value under s.15(1) governs unrelated sales; valuation between related parties per Rule 28; consignment note required for unregistered rec...
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by the contractual stipulations and cannot rely on external understandings or prior correspondence, as these are superseded by Article 32, which mandates written amendment signed by all parties.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by the contractual stipulations and cannot rely on external understandings or prior correspondence, as these are superseded by Article 32, which mandates written amendment signed by all parties.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.
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