Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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by the contractual stipulations and cannot rely on external understandings or prior correspondence, as these are superseded by Article 32, which mandates written amendment signed by all parties.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by the contractual stipulations and cannot rely on external understandings or prior correspondence, as these are superseded by Article 32, which mandates written amendment signed by all parties.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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