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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Notional interest on interest-free tenancy security deposits is not taxable merely because deposits were received: absent a contractual right to interest or evidence that rent was suppressed or substituted, no real income accrues. Capital introduced by an identified partner through verified bank accounts cannot be added in the firm's hands merely because the partner's antecedent source remains doubtful, unless the funds are shown to belong to the firm. A cash-deposit addition must exclude amounts already treated as partner capital, while unreconciled balances require cash-book verification. Expenditure disallowance under section 14A requires exempt income in the relevant year; ad hoc business-expense disallowance also fails without identified non-business expenditure or record defects.
Notional interest on interest-free tenancy security deposits is not taxable merely because deposits were received: absent a contractual right to interest or evidence that rent was suppressed or substituted, no real income accrues. Capital introduced by an identified partner through verified bank accounts cannot be added in the firm's hands merely because the partner's antecedent source remains doubtful, unless the funds are shown to belong to the firm. A cash-deposit addition must exclude amounts already treated as partner capital, while unreconciled balances require cash-book verification. Expenditure disallowance under section 14A requires exempt income in the relevant year; ad hoc business-expense disallowance also fails without identified non-business expenditure or record defects.
Note: It is a system-generated summary and is for quick reference only.
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