The issue was whether reassessment notice issued after six years was valid. The Court upheld that such notices are time-barred and cannot be sustained under law.
The Court examined whether reassessment notice issued beyond limitation was valid. It held that notices issued after expiry of the six-year limit under the old regime are barred and liable to be set aside.
The case examined whether a tube-fed nutritional liquid qualifies as a beverage. Authorities held that its clinical use and lack of consumption as a drink exclude it from beverage classification.
The Court held that reassessment under Sections 147/148 cannot be initiated solely on third-party data without independent evidence of income escapement. It ruled that such reopening amounts to suspicion and lacks the required “reason to believe.”
The Tribunal upheld disallowance of deduction where donations were routed back to donors through layered transactions. The key takeaway is that non-genuine donations do not qualify for tax deduction.
The Supreme Court affirmed that payments for cloud computing services are not royalty where no intellectual property rights are transferred. It held that mere access to services does not amount to use of equipment or technology under tax law.
The Court held that the issue of treating DRP upload as receipt was already settled by earlier rulings. It dismissed the Revenue’s appeals while making the decision subject to the Supreme Court’s final outcome.
The Tribunal held that trading and service activities were inextricably linked and could not be segmented. It accepted entity-level TNMM, rendering TP adjustments unsustainable.
The Tribunal held that TDS credit cannot be denied merely because it does not appear under the assessee’s PAN. It ruled that the assessee cannot be forced to ensure revision of TDS returns by the deductor.
The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh examination on merits. The case was remanded to the Assessing Officer for reconsideration with proper hearing.
