Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Bogus purchase additions under section 69C were discussed in the context of whether the assessee had discharged the burden of proving genuineness; the note states that purchase invoices, supplier ledgers, transport receipts, banking records and regular books supported the transactions, and that a mere reversal of input tax credit did not by itself establish non-genuine purchases. It also addresses reassessment under section 148, stating that notice and the section 148A(d) order were not in accordance with law where the reopening was based on DGGI/Insight information, the material was not supplied to the assessee, and no independent application of mind was shown. The addition and reopening are described as unsustainable on those facts.
Bogus purchase additions under section 69C were discussed in the context of whether the assessee had discharged the burden of proving genuineness; the note states that purchase invoices, supplier ledgers, transport receipts, banking records and regular books supported the transactions, and that a mere reversal of input tax credit did not by itself establish non-genuine purchases. It also addresses reassessment under section 148, stating that notice and the section 148A(d) order were not in accordance with law where the reopening was based on DGGI/Insight information, the material was not supplied to the assessee, and no independent application of mind was shown. The addition and reopening are described as unsustainable on those facts.
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