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...
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Unexplained election expenditure based on a seized notebook requires proof that the document belongs to or is linked with the taxpayer and independent corroboration of its entries. A notebook recovered from separate commission-agent business premises, without the taxpayer's name, verification from named persons, or other correlation, does not by itself establish unexplained expenditure despite the statutory presumption for seized documents. Undated alleged campaign payments must be assessed in the year supported by campaign, polling, search, and entry-related facts; meeting-schedule dates do not establish the year of payment.
Unexplained election expenditure based on a seized notebook requires proof that the document belongs to or is linked with the taxpayer and independent corroboration of its entries. A notebook recovered from separate commission-agent business premises, without the taxpayer's name, verification from named persons, or other correlation, does not by itself establish unexplained expenditure despite the statutory presumption for seized documents. Undated alleged campaign payments must be assessed in the year supported by campaign, polling, search, and entry-related facts; meeting-schedule dates do not establish the year of payment.
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