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...
Limitation for search assessments under a joint warrant was required to be computed person-wise under section 153B read with section 292CC, so the last panchanama in another person's case could not extend time for the assessee; the assessments completed after the statutory period were quashed. Additions based on third-party emails, loose sheets, WhatsApp chats and other electronic material were deleted because the Department failed to prove ownership, nexus, fund flow or corroboration. Estimated commission on alleged bogus sub-contracts and cash-repass theories also failed for want of supporting evidence and cross-examination. Deduction under section 80IA(4) for infrastructure work was upheld on binding precedent.
Limitation for search assessments under a joint warrant was required to be computed person-wise under section 153B read with section 292CC, so the last panchanama in another person's case could not extend time for the assessee; the assessments completed after the statutory period were quashed. Additions based on third-party emails, loose sheets, WhatsApp chats and other electronic material were deleted because the Department failed to prove ownership, nexus, fund flow or corroboration. Estimated commission on alleged bogus sub-contracts and cash-repass theories also failed for want of supporting evidence and cross-examination. Deduction under section 80IA(4) for infrastructure work was upheld on binding precedent.
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