The Court examined whether tax authorities can issue a single order for multiple years. It held that composite orders are invalid and directed separate orders for each year.
The petitioner alleged denial of hearing and cross-examination. The Court ruled that no such violation was established at this stage and deferred such issues to appropriate proceedings.
The case examined whether reassessment proceedings were valid when approval was obtained from an incorrect authority. The Court held the sanction invalid as it did not comply with statutory requirements, rendering the reassessment void. The ruling highlights strict adherence to approval hierarchy in reopening cases.
The court examined cancellation of GST registration issued without stating any reasons. It held such non-speaking orders invalid and restored registration, emphasizing that reasoned orders are mandatory.
The Tribunal ruled that the Department failed to prove that goods classified as trading were actually manufactured by the assessee. In absence of proper investigation, excise demand and penalties were held unsustainable.
The Supreme Court declined to condone delay, thereby upholding the High Court’s conclusion that the liaison office did not constitute a PE. The High Court found activities to be preparatory in nature. The ruling highlights strict standards for establishing PE in India.
The judgment confirms that income from offshore equipment supply is not taxable where transactions occur outside India. The liaison office was also held not to create a taxable presence. The case highlights limits of tax jurisdiction over cross-border supplies.
The Tribunal held that lack of awareness of the assessment order and limited knowledge of tax law constituted sufficient cause for delay. The matter was restored for reconsideration on merits.
The Tribunal confirmed addition of unexplained investments where the assessee could not substantiate the source of deposits. The ruling reinforces the burden of proof on the taxpayer.
The Tribunal held that wage arrears arising from pay revision constitute an accrued liability from the effective date. The provision was allowed despite later payment and quantification.
