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...
Taxability of interest under a flat buy-back arrangement turns on the actual repayment sequence and the income credited in the assessee's hands. Where documents, including the payer's email and remand material, showed that principal was to be repaid first and premium or interest only thereafter, the Assessing Officer could not treat the outstanding balance as interest already received or accrued without evidence that the full premium component had been paid. TDS credit was also noted as admissible only when the corresponding income is offered to tax, and the disputed addition was deleted.
Taxability of interest under a flat buy-back arrangement turns on the actual repayment sequence and the income credited in the assessee's hands. Where documents, including the payer's email and remand material, showed that principal was to be repaid first and premium or interest only thereafter, the Assessing Officer could not treat the outstanding balance as interest already received or accrued without evidence that the full premium component had been paid. TDS credit was also noted as admissible only when the corresponding income is offered to tax, and the disputed addition was deleted.
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