Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
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Effective 1 October 2026, the TDS compliance framework extends to consideration for transfer of immovable property where a resident individual or HUF must deduct tax under section 393(2). Rules 215, 218 and 219 now require the relevant TDS certificate, deposit and statement reporting for such transactions. Form 132 and Form 141 are amended to cover property transfers involving non-resident sellers and resident individual or HUF buyers. New Schedule E in Form 141 requires property, buyer, seller, consideration, instalment and tax-deduction details. Non-resident seller reporting requires contact details, overseas address, tax residency certificate and tax identification information, including where PAN is unavailable.
Effective 1 October 2026, the TDS compliance framework extends to consideration for transfer of immovable property where a resident individual or HUF must deduct tax under section 393(2). Rules 215, 218 and 219 now require the relevant TDS certificate, deposit and statement reporting for such transactions. Form 132 and Form 141 are amended to cover property transfers involving non-resident sellers and resident individual or HUF buyers. New Schedule E in Form 141 requires property, buyer, seller, consideration, instalment and tax-deduction details. Non-resident seller reporting requires contact details, overseas address, tax residency certificate and tax identification information, including where PAN is unavailable.
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