Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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Amounts paid for technical know-how, engineering and post-importation assistance are includible in assessable value only if they are shown to be a condition of sale of the imported goods. The contract here separately allocated obligations and consideration between technical services and supply of key equipment, with separate invoices and no contractual nexus proving that the services were a precondition for purchase of the imported machinery. The Tribunal therefore held that the separately contracted licence, engineering and technical assistance charges were not part of the transaction value of the imported plant and equipment, and could not be added to assessable value.
Amounts paid for technical know-how, engineering and post-importation assistance are includible in assessable value only if they are shown to be a condition of sale of the imported goods. The contract here separately allocated obligations and consideration between technical services and supply of key equipment, with separate invoices and no contractual nexus proving that the services were a precondition for purchase of the imported machinery. The Tribunal therefore held that the separately contracted licence, engineering and technical assistance charges were not part of the transaction value of the imported plant and equipment, and could not be added to assessable value.
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