https://www.taxtmi.com/caselaws?id=792772 Equalization levy cannot be extended to reimbursements paid by an Indian assessee to its overseas subsidiary for online advertising expenses where the statutory charging provision covers consideration received by a non-resident for specified services and does not expressly include reimbursement. The corporate veil of the subsidiary cannot be pierced without proof that the structure was a sham or device for impropriety or tax evasion; prior existence of the subsidiary and earlier reimbursement arrangements weighed against such a finding. Statements recorded during survey under the Income-tax Act, standing alone, are insufficient to fasten liability. On these grounds, the refund rejection was set aside and reconsideration directed. en-us Mon, 01 Jun 2026 00:00:00 +0530 Wed, 03 Jun 2026 08:50:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792772 Equalization levy cannot be extended to reimbursements paid by an Indian assessee to its overseas subsidiary for online advertising expenses where the statutory charging provision covers consideration received by a non-resident for specified services and does not expressly include reimbursement. The corporate veil of the subsidiary cannot be pierced without proof that the structure was a sham or device for impropriety or tax evasion; prior existence of the subsidiary and earlier reimbursement arrangements weighed against such a finding. Statements recorded during survey under the Income-tax Act, standing alone, are insufficient to fasten liability. On these grounds, the refund rejection was set aside and reconsideration directed. Case-Laws Income Tax Mon, 01 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792772