Misdeclaration of quantity rejected where supplier evidence established counting errors, so reassessment, confiscation and redemption fine were set as...
Admissibility of electronic evidence controls valuation and penalty exposure; non compliant e records and statements nullify revaluation and penalties...
Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee's own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.
Franchise fee paid to secure participation rights in the Indian Premier League was treated as revenue expenditure, as the Tribunal followed coordinate bench decisions in the assessee's own earlier years and found no distinguishing feature or reversal of those rulings. The alternative depreciation claim was therefore academic. On payments to a New Zealand resident talent scout, the Tribunal found the arrangement prima facie consistent with independent personal services under Article 14 of the India-New Zealand DTAA and noted that the 183-day condition was satisfied, but remanded the matter for limited verification of whether the consultant had a fixed base in India. If Article 14 conditions are met, no TDS liability arises.
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