The Tribunal held that receipts from sponsorship and royalty were incidental to the promotion of sports. It ruled that absence of profit motive prevented application of the proviso to section 2(15), allowing exemption under sections 11 and 12.
The Tribunal set aside the demand as time-barred and unsupported by evidence beyond third-party income tax data. It held that absence of fraud or suppression invalidated extended limitation.
The Tribunal addressed disallowance arising from mismatch between ITR and tax audit report. It held that inadvertent reporting errors require verification, not outright denial of deduction.
The issue highlights mandatory annual return filing for LLPs. The key takeaway is that delayed filing attracts heavy daily penalties, making timely compliance essential.
The case involved additions for unexplained bank deposits where the assessee later produced authenticated NRE account evidence. ITAT remanded the matter, directing fresh consideration of documents and proper opportunity of hearing.
The Court dismissed the SLP due to a 390-day delay and absence of valid grounds. The ruling leaves intact the finding that interconnect payments are not royalty.
The High Court followed its earlier ruling that interconnect service charges are not taxable as royalty. The Revenues appeal was dismissed due to lack of merit and binding precedent.
The Court declined to interfere after finding no sufficient reason to disturb the High Court’s decision. The ruling reinforces limits on appellate intervention.
The Court set aside Section 148 notices after finding no tangible evidence supporting the existence of a Permanent Establishment. The ruling highlights the need for concrete material in reassessment.
The Tribunal rejected the refund claim after finding that export proceeds exceeded the declared FOB value. It held that such excess creates a presumption of duty being passed on, barring refund.
