Gujarat High Court held that the duty free import of “Walnut Inshell” against the entry of “Dietary Fibres” in the DFIA license issued under SION Norms E-5 for export Biscuits is permissible. Appeal stands disposed of, accordingly.
The issue was restricted access to bullion imports through IFSC. The circular widens eligibility and clarifies compliance, easing imports while retaining regulatory safeguards.
The assessee demonstrated that the ₹1.03 crore cash deposit arose from opening cash balance and collections from sundry debtors. The Tribunal held that the onus stood discharged and deleted the entire addition.
ITAT held that CPC cannot increase dividend income based on Schedule BP entries, restricting taxable dividend to the amount correctly disclosed in the return and upholding section 115BBDA exemption.
From FY 2025–26, partnership firms must deduct 10% TDS on specified payments to partners once the ₹20,000 threshold is crossed, with strict timelines for deduction and reporting.
The Assessing Officer proceeded with reassessment after three years based solely on PCIT approval. The Tribunal emphasized that compliance with Section 151 is mandatory, and failure renders the notice under Section 148 void.
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Reassessment was quashed as the statutory process under the faceless regime was not followed end-to-end by the same authority. Such jurisdictional inconsistency vitiates the entire proceedings.
The Tribunal held that reassessment initiated solely on a Revenue audit objection, without fresh tangible material, is invalid. Reopening beyond four years on the same facts examined earlier amounts to impermissible change of opinion.
Where income admitted in section 153C proceedings is accepted in assessment, penalty still requires strict compliance with section 270A. Absence of a specific misreporting charge defeats penalty levy.
