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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Settlement under the Direct Tax Vivad Se Vishwas Scheme, 2020 was confined to the dispute from the original assessment, as confirmed by the declaration, Form No. 5 and Assessing Officer verification. Subsequently initiated reassessment proceedings did not fall within that settlement, so dismissal on the premise that the reassessment dispute stood settled was set aside. The reassessment addition for alleged bogus purchases was deleted because the identities of suppliers, transaction-wise details, invoices and supporting material were not disclosed, leaving no clear factual basis for the addition.
Settlement under the Direct Tax Vivad Se Vishwas Scheme, 2020 was confined to the dispute from the original assessment, as confirmed by the declaration, Form No. 5 and Assessing Officer verification. Subsequently initiated reassessment proceedings did not fall within that settlement, so dismissal on the premise that the reassessment dispute stood settled was set aside. The reassessment addition for alleged bogus purchases was deleted because the identities of suppliers, transaction-wise details, invoices and supporting material were not disclosed, leaving no clear factual basis for the addition.
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