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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Reassessment initiated on specific Investigation Wing information about substantial cash deposits was sustained where the Assessing Officer examined the information and formed a belief that income had escaped assessment. Recording cash receipts as sales did not by itself establish that corresponding bank deposits arose from business sales; reliable linkage among the sales, stock movement and deposits was required to rebut an unexplained cash-credit addition. A challenge to mere initiation of penalty proceedings was premature, while interest levied consequentially on the assessment followed the assessment outcome.
Reassessment initiated on specific Investigation Wing information about substantial cash deposits was sustained where the Assessing Officer examined the information and formed a belief that income had escaped assessment. Recording cash receipts as sales did not by itself establish that corresponding bank deposits arose from business sales; reliable linkage among the sales, stock movement and deposits was required to rebut an unexplained cash-credit addition. A challenge to mere initiation of penalty proceedings was premature, while interest levied consequentially on the assessment followed the assessment outcome.
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