Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
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Royalty on export sales required fresh examination because the Tribunal found that the source of income must be distinguished from the source of receipt, but the Assessing Officer had not fully verified where the export contracts were concluded or whether the royalty was taxed in another jurisdiction; the issue was remanded without final merits adjudication. Management support services were held not to be fee for technical services under the India-Singapore DTAA because that agreement operated independently from the royalty/licensing arrangement, and the assessee succeeded on that issue for all years. On reimbursement of expenses, the DRP lacked power under section 144C(8) to direct further enquiry and fresh determination by the Assessing Officer, so those directions were invalid and the related addition for AY 2022-23 was deleted.
Royalty on export sales required fresh examination because the Tribunal found that the source of income must be distinguished from the source of receipt, but the Assessing Officer had not fully verified where the export contracts were concluded or whether the royalty was taxed in another jurisdiction; the issue was remanded without final merits adjudication. Management support services were held not to be fee for technical services under the India-Singapore DTAA because that agreement operated independently from the royalty/licensing arrangement, and the assessee succeeded on that issue for all years. On reimbursement of expenses, the DRP lacked power under section 144C(8) to direct further enquiry and fresh determination by the Assessing Officer, so those directions were invalid and the related addition for AY 2022-23 was deleted.
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