Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
ITAT allowed the assessee's appeal and quashed the revisionary order passed by PCIT u/s 263. It held that once the assessee opted for and finalized settlement under the Direct Tax Vivad Se Vishwas Act, 2020, the tax dispute stood conclusively closed and could not be reopened through revision proceedings u/s 263. Relying on binding HC precedent, ITAT concluded that the PCIT's exercise of jurisdiction was contrary to the scheme and object of the Vivad Se Vishwas Act, rendering the impugned revisional order unsustainable in law.
ITAT allowed the assessee's appeal and quashed the revisionary order passed by PCIT u/s 263. It held that once the assessee opted for and finalized settlement under the Direct Tax Vivad Se Vishwas Act, 2020, the tax dispute stood conclusively closed and could not be reopened through revision proceedings u/s 263. Relying on binding HC precedent, ITAT concluded that the PCIT's exercise of jurisdiction was contrary to the scheme and object of the Vivad Se Vishwas Act, rendering the impugned revisional order unsustainable in law.
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