Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
Primary issue was whether assets received under a scheme of demerger attracted deemed income u/s 56(2)(x) because the demerger allegedly violated Section 2(19AA) and the swap ratio/valuation contravened Rule 11UA. Tribunal held Section 2(19AA)(iv) mandates proportionate share allotment only, Rule 11UA cannot be read into Section 2(19AA), the registered valuer's computation was reasonable and the scheme complied with Section 2(19AA) read with Section 47(vi); consequence: addition u/s 56(2)(x) deleted. Separately, payment under an unregistered MOU was not a "specified agreement" attracting TDS u/s 194IC; consequence: no TDS liability. - ITAT
Primary issue was whether assets received under a scheme of demerger attracted deemed income u/s 56(2)(x) because the demerger allegedly violated Section 2(19AA) and the swap ratio/valuation contravened Rule 11UA. Tribunal held Section 2(19AA)(iv) mandates proportionate share allotment only, Rule 11UA cannot be read into Section 2(19AA), the registered valuer's computation was reasonable and the scheme complied with Section 2(19AA) read with Section 47(vi); consequence: addition u/s 56(2)(x) deleted. Separately, payment under an unregistered MOU was not a "specified agreement" attracting TDS u/s 194IC; consequence: no TDS liability. - ITAT
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