Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
TDS under s. 194C is attracted at the earlier of credit or payment. Since the liability for external development charges arose on credit in AY 2012-13, any default under s. 201(1) and interest under s. 201(1A) could be fastened only for AY 2012-13; the assessee could not be treated as an assessee-in-default for AY 2014-15 for the same amounts. Further, applying s. 201(3), the limitation ran from the relevant credit event, and the last date to pass an order was 31-03-2019; the order dated 25-03-2021 was time-barred and was set aside. - ITAT
TDS under s. 194C is attracted at the earlier of credit or payment. Since the liability for external development charges arose on credit in AY 2012-13, any default under s. 201(1) and interest under s. 201(1A) could be fastened only for AY 2012-13; the assessee could not be treated as an assessee-in-default for AY 2014-15 for the same amounts. Further, applying s. 201(3), the limitation ran from the relevant credit event, and the last date to pass an order was 31-03-2019; the order dated 25-03-2021 was time-barred and was set aside. - ITAT
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