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...
Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years.
Reimbursement of actual staff salary cost from a project office to its head office, with no mark-up, was treated as a payment to self because both formed parts of the same enterprise. On that reasoning, no taxable income arose from the internal allocation, and the amount could not be assessed separately as fees for technical services. The Tribunal followed its earlier view that a transaction between the project office and head office did not generate income in the absence of any element of profit. The addition was deleted for both assessment years.
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