Packing-material input credits support inverted-duty refunds for packaged tea, while rate-reduction and concessional-supply circulars remain inapplica...
Government road-restoration services for commercial pipeline work attract reverse-charge GST, while portal-issued proceedings remain valid without a p...
Gains from share and securities sales retained their capital-gains character because no factual distinction from later assessment years justified recharacterisation as business income. Import-purchase payments to a Japanese non-resident associated enterprise remained free from withholding-tax disallowance, as identical later-year determinations governed the issue. Rule 8D could not support an additional section 14A administrative-expenditure disallowance unless the Assessing Officer examined the accounts, recorded dissatisfaction with the taxpayer's own disallowance, and identified expenditure related to exempt income. Formulaic application without these steps required deletion of the additional disallowance. The Revenue's appeal failed, while the taxpayer's appeal succeeded on section 14A.
Gains from share and securities sales retained their capital-gains character because no factual distinction from later assessment years justified recharacterisation as business income. Import-purchase payments to a Japanese non-resident associated enterprise remained free from withholding-tax disallowance, as identical later-year determinations governed the issue. Rule 8D could not support an additional section 14A administrative-expenditure disallowance unless the Assessing Officer examined the accounts, recorded dissatisfaction with the taxpayer's own disallowance, and identified expenditure related to exempt income. Formulaic application without these steps required deletion of the additional disallowance. The Revenue's appeal failed, while the taxpayer's appeal succeeded on section 14A.
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TaxTMI 
TaxTMI 
of 4905 
