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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Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.
Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.
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