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...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
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Statutory timelines for disposal of income-tax appeals prevail over administrative circulars that assign priority categories for out-of-turn disposal. Where the prescribed timeline has not been followed, pending appeals must be decided expeditiously and cannot be deferred solely because they do not fall within an administrative priority category. The appellate authority must provide a proper and reasonable opportunity of hearing and dispose of the pending appeals within three months, without adjudication of their merits at this stage.
Statutory timelines for disposal of income-tax appeals prevail over administrative circulars that assign priority categories for out-of-turn disposal. Where the prescribed timeline has not been followed, pending appeals must be decided expeditiously and cannot be deferred solely because they do not fall within an administrative priority category. The appellate authority must provide a proper and reasonable opportunity of hearing and dispose of the pending appeals within three months, without adjudication of their merits at this stage.
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