Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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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