Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Replacement of dies and moulds was treated as revenue expenditure under current repairs principles, while temporary structural and interior works were accepted as non-enduring and not capital in nature. Weighted deduction for research expenditure on work in progress was allowed on the basis of earlier precedent. Entry tax remained deductible under income tax law despite set-off under sales tax law, and the discount on prepayment of deferred sales tax on an NPV basis was held capital, not income. Amounts paid to foreign entities for ECB-related services were not taxable under the applicable DTAA because the make-available test was not satisfied, so no TDS liability arose. Prior final orders on foreign commission disallowance were followed, and the appeal was dismissed.
Replacement of dies and moulds was treated as revenue expenditure under current repairs principles, while temporary structural and interior works were accepted as non-enduring and not capital in nature. Weighted deduction for research expenditure on work in progress was allowed on the basis of earlier precedent. Entry tax remained deductible under income tax law despite set-off under sales tax law, and the discount on prepayment of deferred sales tax on an NPV basis was held capital, not income. Amounts paid to foreign entities for ECB-related services were not taxable under the applicable DTAA because the make-available test was not satisfied, so no TDS liability arose. Prior final orders on foreign commission disallowance were followed, and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.