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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The statutory notification exempting interest payments to corporations established under Central, State or Provincial Acts applies to the National Highways Authority of India as a Central Act corporation. CBDT Circular No. 18/2017, which concerns entities with unconditionally exempt income, cannot add conditions to or narrow that statutory notification. Accordingly, interest paid on mobilisation advances to the Authority is not subject to tax deduction at source, and the payer cannot be treated as an assessee-in-default or charged consequential interest.
The statutory notification exempting interest payments to corporations established under Central, State or Provincial Acts applies to the National Highways Authority of India as a Central Act corporation. CBDT Circular No. 18/2017, which concerns entities with unconditionally exempt income, cannot add conditions to or narrow that statutory notification. Accordingly, interest paid on mobilisation advances to the Authority is not subject to tax deduction at source, and the payer cannot be treated as an assessee-in-default or charged consequential interest.
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