Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
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...
Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.
Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
