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    Offshore supply profits escaped Indian taxation where no fixed-place PE existed and supervisory activities lacked transactional connection.
    Comparable Uncontrolled Price benchmarking prevailed where reliable preform silica data existed, eliminating the adjustment based on TNMM.
    Valid concealment penalty initiation requires assessment-stage satisfaction; future intent and belated notices cannot create jurisdiction.
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      Order sets aside impugned adjudication and remits the matter for...

      Overlap of tax assessments requires remand for fresh adjudication; taxpayers must particularize and substantiate pre GST transactions.

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      GSTFebruary 26, 2026Case LawsHC
      Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.

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      ActsIncome Tax