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Home e-Newsletters Index Year 2025 March Day 17 - Monday

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TMI Tax Updates - e-Newsletter
March 17, 2025

Case Laws in this Newsletter:

GST Income Tax Customs Corporate Laws Insolvency & Bankruptcy FEMA PMLA Service Tax Central Excise CST, VAT & Sales Tax Indian Laws



TMI Short Notes

1. Full value of consideration / Stamp Duty Valuation with Safe Harbor - Computation of Capital Gains: Clause 78 of the Income Tax Bill, 2025 vs. Section 50C of the Income-tax Act, 1961

Bill:

Summary: Clause 78 of the Income Tax Bill, 2025, and Section 50C of the Income-tax Act, 1961, aim to ensure that property transaction values reflect true market values by using the stamp duty valuation as the full value of consideration when declared values are lower. Both provisions include a 110% safe harbor threshold to accommodate minor discrepancies and allow taxpayers to contest valuations through a Valuation Officer if necessary. These measures are designed to prevent tax evasion through undervaluation, thereby promoting transparent real estate transactions and ensuring fair tax assessments. Differences in procedural references exist, but the core intent remains aligned.

2. Capital Gains Taxation in Slump Sales: Clause 77 of the Income Tax Bill, 2025 vs. Section 50B of the Income Tax Act, 1961

Bill:

Summary: Clause 77 of the Income Tax Bill, 2025, introduces provisions for computing capital gains in slump sales, aligning with Section 50B of the Income Tax Act, 1961. It categorizes gains as long-term or short-term based on asset holding periods, ensuring consistency with capital gains taxation principles. Both provisions determine net worth by subtracting liabilities from total assets, ignoring revaluation changes, and require fair market value assessments. Reporting by an accountant is mandated for accuracy. While similar, Clause 77 offers refinements reflecting updated accounting practices, ensuring clarity and consistency in tax liabilities for slump sales.

3. Computation of capital gains in case of Market Linked Debenture: Clause 76 of the Income Tax Bill, 2025 vs. Section 50AA of the Income Tax Act, 1961

Bill:

Summary: Clause 76 of the Income Tax Bill, 2025, introduces specific provisions for calculating capital gains on Market Linked Debentures (MLDs), treating all gains as short-term regardless of the holding period. This aims to standardize tax treatment, prevent tax avoidance, and ensure fair taxation of speculative investments. It overrides certain existing provisions, defines relevant capital assets, and provides a formula for gain computation. It also disallows securities transaction tax deductions. While similar to Section 50AA of the Income Tax Act, 1961, Clause 76 has a broader scope, including unlisted bonds and debentures, reflecting updated policy considerations.

4. Cost of acquisition in case of depreciable asset: Clause 75 of the Income Tax Bill, 2025 vs. Section 50A of the Income Tax Act, 1961

Bill:

Summary: Clause 75 of the Income Tax Bill, 2025, introduces changes to the calculation of capital gains for depreciable assets by adjusting the cost of acquisition to reflect the asset's depreciated value. This aims to prevent tax avoidance by ensuring accurate capital gains calculations and aligning tax liabilities with economic realities. It contrasts with Section 50A of the Income Tax Act, 1961, which also adjusts the cost of acquisition for depreciable assets but references different sections for its application. Clause 75's integration with Sections 72 and 73 suggests a broader approach to managing capital gains and losses, enhancing tax planning opportunities.


Articles

1. Agency or Principal-to-Principal Basis? The Taxing Dilemma in Business Transactions

   By: Somesh Jain

Summary: The distinction between agency and principal-to-principal relationships in business transactions is crucial due to its significant tax implications under both direct and indirect tax laws. The Supreme Court recently addressed this issue in a case involving a lottery distributor, determining that despite being labeled as an agent, the distributor acted on a principal-to-principal basis, thus not subject to service tax. This decision underscores that the true nature of a transaction is determined by the substance of the agreement rather than its terminology. Courts emphasize evaluating the entire agreement to understand the rights and liabilities of the parties involved.

2. FTWZ vs Customs Bonded Warehouse: Which One’s Right for Your Imports?

   By: Pradeep Reddy

Summary: The article compares Free Trade and Warehousing Zones (FTWZ) and Customs Bonded Warehouses (CBW) to help businesses decide which is more suitable for their import needs. FTWZs offer duty deferment until goods exit the zone, are ideal for re-exports and global distribution, and have no storage time limits. CBWs allow goods to be stored with zero upfront duty, are perfect for domestic sales and imports, but have limited storage periods. The choice depends on whether the business focuses on re-exporting and global distribution or domestic sales and imports.

3. 🚛 Can GTA service providers use both 5% and 12% GST under forward charge?

   By: Pradeep Reddy

Summary: GTA service providers can apply both 5% and 12% GST rates under the forward charge mechanism, depending on the nature of the consignments. The 5% rate is applicable without Input Tax Credit (ITC) for exempt supplies, while the 12% rate allows ITC for taxable supplies. Providers must choose a consistent rate for the entire financial year. The decision to use either rate should consider the business benefits of ITC availability against potential customer demand for lower rates. This flexibility allows providers to strategically manage their tax liabilities and optimize their service offerings.

4. Difference Between ROC Filing for Pvt. Ltd and LLP

   By: Ishita Ramani

Summary: Registrar of Companies (ROC) filing is mandatory for both Private Limited Companies (Pvt. Ltd) and Limited Liability Partnerships (LLPs) in India, with distinct requirements for each. Pvt. Ltd companies adhere to the Companies Act, 2013, filing forms MGT 7 and AOC 4 within specific deadlines post-AGM, and require mandatory audits. LLPs follow the LLP Act, 2008, filing forms LLP 11 and LLP 8 by fixed dates, with audits only if financial thresholds are exceeded. Both entities incur penalties for late filing. Timely compliance ensures legal adherence, transparency, and facilitates business operations. Pvt. Ltd companies face stricter filing demands compared to LLPs.

5. LEGAL TERMINOLOGY IN GST LAW (PART 12)

   By: Dr. Sanjiv Agarwal

Summary: Compounding in GST law refers to the payment of a monetary fine instead of undergoing prosecution for an offence. It is a legal arrangement where the offender pays a penalty to avoid prosecution, acting as a compromise between the offender and the state. The GST Act allows compounding of offences by the Commissioner upon payment, either before or after prosecution begins, with specific conditions such as payment of due taxes, interest, and penalties. Compounding decisions are discretionary and cannot be appealed or reopened. This process ensures revenue for the state while granting immunity from prosecution to the offender.

6. LIMITATION FOR FILING AN APPLICATION FOR CHALLENGING AN ARBITRAL AWARD UNDER SECTIO 34 OF THE ARBITRATION AND CONCILITION ACT, 1996

   By: DR.MARIAPPAN GOVINDARAJAN

Summary: The article discusses the legal framework for challenging an arbitral award under Section 34 of the Arbitration and Conciliation Act, 1996, focusing on the limitation period for filing such applications. The Supreme Court case of a dispute between two companies highlights the intricacies of the limitation period, including the application of Section 4 of the Limitation Act and Section 10 of the General Clauses Act. The Supreme Court ruled that Section 4 applies to the initial 3-month limitation period but not to the additional 30-day condonable period. Consequently, the appellant's application was dismissed as it was filed beyond the permissible timeframe.

7. Greenwashing by Sugary Soda Producers: The Deceptive Marketing Tactics in the Beverage Industry.

   By: YAGAY andSUN

Summary: The beverage industry, particularly sugary soda producers, is increasingly using greenwashing tactics to mislead consumers about their environmental and health impacts. Companies claim eco-friendly packaging and healthier product options, yet these efforts are often exaggerated or deceptive. Despite promoting recyclable materials and plant-based plastics, the industry's contribution to plastic pollution remains significant. Healthier product claims often mask the presence of artificial sweeteners and other harmful ingredients. Sustainability claims regarding carbon footprint and water use are frequently overstated. Media and watchdog organizations have exposed these deceptive practices, highlighting the need for greater transparency and accountability in the industry.

8. Flue Gas: MOEFCC, CPCB,  and SPCB - Roles and Responsibilities in Mitigating Emissions.

   By: YAGAY andSUN

Summary: Flue gas emissions from industrial activities are a major source of air pollution in India. The Ministry of Environment, Forest and Climate Change (MOEFCC), the Central Pollution Control Board (CPCB), and the State Pollution Control Boards (SPCBs) are responsible for managing these emissions. The MOEFCC formulates policies and sets national standards, the CPCB develops technical guidelines and monitors compliance, and the SPCBs enforce local implementation and ensure industries adopt pollution control technologies. Together, they work to improve air quality by promoting cleaner technologies, monitoring emissions, and enforcing regulations to mitigate the environmental and health impacts of flue gas.

9. Flue Gas - The Hidden Devil (Environmental Laws)

   By: YAGAY andSUN

Summary: Flue gas, emitted from industrial processes like fuel combustion, is a significant environmental and health hazard. It contains harmful substances such as carbon dioxide, nitrogen oxides, sulfur dioxide, particulate matter, carbon monoxide, volatile organic compounds, and heavy metals. These contribute to air pollution, acid rain, climate change, and health issues like respiratory and cardiovascular diseases. Mitigation strategies include flue gas desulfurization, selective catalytic reduction, electrostatic precipitators, baghouse filters, carbon capture and storage, fuel switching, and energy efficiency improvements. Adopting these technologies and adhering to emission standards can significantly reduce the negative impacts of flue gas.

10. Flue Gas – An Introduction (Environmental Laws)

   By: YAGAY andSUN

Summary: Flue gas, emitted from burning fossil fuels or biomass in industrial processes, comprises various gases and particulates, including carbon dioxide, water vapor, nitrogen, oxygen, sulfur dioxide, nitrogen oxides, carbon monoxide, particulate matter, volatile organic compounds, and heavy metals. These emissions can adversely affect the environment and human health, contributing to climate change, acid rain, and air pollution. To mitigate these impacts, industries employ flue gas treatment methods like desulfurization, selective catalytic reduction, electrostatic precipitators, fabric filters, activated carbon injection, and carbon capture and storage. Regulatory bodies enforce strict emission standards to control these pollutants.

11. Guide to Exporting of Restricted Goods and Chemicals from India

   By: YAGAY andSUN

Summary: Exporting restricted goods and chemicals from India is a complex process requiring strict adherence to regulations set by the Directorate General of Foreign Trade (DGFT) and other authorities. This guide outlines the steps needed, including obtaining export licenses, complying with SCOMET regulations, and ensuring documentation is accurate and complete. Exporters must also follow international standards and obtain necessary certifications. Non-compliance can result in severe legal, financial, and reputational consequences. Key documents include export licenses, SCOMET applications, registration certificates, and various customs forms, all essential for ensuring a smooth export process.

12. DGFT Issues SOP for Voluntary Disclosure of SCOMET Export Violations

   By: YAGAY andSUN

Summary: The Directorate General of Foreign Trade (DGFT) has issued a Standard Operating Procedure (SOP) for voluntary disclosure of violations related to the export of Special Chemicals, Organisms, Materials, Equipment, and Technologies (SCOMET). These dual-use items are strictly regulated. Exporters are encouraged to disclose violations such as unauthorized exports, unintentional exports to sanctioned entities, and non-compliance with licensing requirements. Disclosures are reviewed by an Inter-Ministerial Working Group, considering factors like intent and corrective measures. While voluntary disclosures may lead to favorable outcomes, penalties may still apply. The guidelines aim to enhance compliance and transparency in export control.

13. What is Advance Ruling?

   By: YAGAY andSUN

Summary: An Advance Ruling in Indian law allows businesses to seek preliminary clarifications on legal questions related to customs and GST before transactions occur. It helps ensure compliance, avoid penalties, and minimize litigation by resolving classification, valuation, and taxability issues upfront. Businesses can apply for an Advance Ruling to determine the correct classification and valuation of goods, eligibility for exemptions, and tax obligations. The ruling is binding on both the applicant and tax authorities, providing legal certainty and aiding in financial planning. It enables businesses to optimize operations by taking full advantage of duty exemptions and incentives.


News

1. After popcorn, now turn of donuts to get afflicted by 'GSTitis': Congress

Summary: The Congress criticized the government over differential GST rates, highlighting a Rs 100 crore tax notice issued to Mad Over Donuts for allegedly misclassifying its business to pay lower GST. The issue, now in the Bombay High Court, underscores the complexity of the current GST system. Congress emphasized the need for a simplified GST 2.0, as outlined in their 2024 manifesto, contrasting with Finance Minister Nirmala Sitharaman's stance on rate reductions. This follows previous criticism of GST's complexity, exemplified by varying tax slabs on popcorn.

2. Senate approves funding bill hours before shutdown deadline, sending to Trump for signature

Summary: The Senate passed a six-month spending bill just before a government shutdown, sending it to President Trump for approval. The vote, largely along party lines, highlighted Democratic concerns about the Trump administration's influence over spending and potential cuts to key programs. Despite opposition, some Democrats supported the bill to avoid a shutdown, fearing it would allow the administration to further dismantle government services. The bill reduces non-defense spending by $13 billion and increases defense spending by $6 billion. Democrats criticized the bill as a "blank cheque" for Trump, while Republicans argued Democrats were risking a shutdown for political reasons.

3. DMK Budget eyes 2026 polls, no solutions for people's problems, says AIADMK gen secy

Summary: The Tamil Nadu Budget for 2025-26, presented by the DMK government, has been criticized by the AIADMK and BJP for not addressing key issues such as the promise to abolish NEET and for lacking clarity on funding for announced projects. AIADMK's general secretary accused the budget of being election-focused, while BJP leaders labeled it an "eyewash," citing an alleged symbol controversy and kickback claims related to TASMAC liquor outlets. The opposition parties claim the budget fails to address the state's debt situation and accuse the DMK government of losing credibility.

4. DMK govt presents budget, AIADMK asks govt to resign over TASMAC 'scam'

Summary: The Tamil Nadu government, led by the DMK, presented its 2025-26 budget, focusing on welfare schemes such as fare-free bus travel for women and a monthly assistance program for women. The budget includes significant allocations for infrastructure, including new airports and metro projects, and addresses education funding challenges due to withheld central funds over policy disagreements. The opposition AIADMK staged a walkout, demanding the government's resignation over alleged corruption in the state-run liquor corporation TASMAC. The budget also outlines plans for new industrial hubs and infrastructure development to boost the state's economy.

5. DMK regime presents Budget 2025-26 in Tamil Nadu Assembly

Summary: The DMK government in Tamil Nadu presented its 2025-26 Budget, emphasizing significant allocations for welfare schemes, including a Rs 3,600 crore subsidy for fare-free bus travel benefiting 65% of women commuters. The budget also allocates Rs 13,807 crore for the "Kalaignar Magalir Urimai Thittam" scheme, providing Rs 1,000 monthly assistance to 1.15 crore women. Despite opposition protests over alleged corruption in TASMAC, the government announced infrastructure projects, including a new airport near Chennai and various educational initiatives. Funds have been reallocated due to withheld federal funds over policy disagreements, particularly regarding the New Education Policy.

6. Keynote Address by Shri Sanjay Malhotra, Governor, Reserve Bank of India at the Policy Seminar on Climate Change Risks and Finance organised by Reserve Bank of India, March 13, 2025, New Delhi

Summary: The Governor of the Reserve Bank of India addressed climate change risks and their impact on the financial system at a policy seminar. He emphasized the dual dimensions of climate risks: facilitating green finance and managing prudential risks. The Reserve Bank aims to support green finance through initiatives like priority sector lending and the creation of a Climate Risk Information System. The bank is developing guidelines for climate risk disclosures and plans to enhance technical expertise in risk management. Collaboration with international bodies and domestic entities is crucial for a cohesive approach to mitigating climate change impacts on the economy.

7. Govt to assist exporters overcome global challenges: Shri Piyush Goyal

Summary: The Union Minister of Commerce & Industry assured exporters that the government is committed to supporting them amid global challenges. Efforts are underway to finalize free trade agreements (FTAs) to enhance opportunities and investments for Indian exporters. The Minister encouraged exporters to adopt a bold approach, moving away from protectionism, to strengthen India's global trade position. The Viksit Bharat Mission aims for prosperity by aligning industry commitment with consumer aspirations. With India projected to surpass $800 billion in exports, the Minister urged exporters to strive for $900 billion next year. Emphasis was placed on engaging with the US and utilizing the Export Promotion Mission.

8. Creators are India’s digital ambassadors, should take India story to the world: Shri Piyush Goyal

Summary: Union Minister of Commerce & Industry, Shri Piyush Goyal, addressed the RISE//DEL Conference 2025, urging India's creative industry to act as digital ambassadors and share India's story globally. He highlighted the importance of responsible content, innovative storytelling, skill development, and exporting Indian creativity. Goyal emphasized the role of digital innovation and low-cost data in empowering creators and startups. He encouraged leveraging new technologies and collaborations to expand India's cultural footprint and boost tourism. Goyal reiterated the government's support in fostering creativity and invited global collaboration to enhance India's presence in the creative sector.

9. 89th Meeting of Network Planning Group under PM GatiShakti evaluates key infrastructure projects

Summary: The 89th meeting of the Network Planning Group, chaired by a Joint Secretary from the Department for Promotion of Industry and Internal Trade, evaluated eight infrastructure projects in the Road, Railway, and Metro sectors. These projects, aligned with the PM GatiShakti National Master Plan, aim to enhance multimodal connectivity and logistics efficiency. Key projects include a two-lane highway in Meghalaya, a four-lane tunnel under the Brahmaputra, highway upgrades in Assam and Rajasthan, railway expansions in Maharashtra and Odisha, and the Rajkot Metro in Gujarat. These initiatives are expected to improve connectivity, reduce travel times, and boost socio-economic development.

10. State’s Own Tax Revenue set to grow at 14.60 percent, says FM Thangam Thennarasu

Summary: Tamil Nadu's State Own Tax Revenue (SOTR) is projected to grow by 14.60% in 2025-26, driven by economic activity, tax revisions, and improved collection efficiency. The SOTR for 2025-26 is estimated at Rs 2,20,895 crore, with significant contributions from commercial taxes, stamps, registration, motor vehicle taxes, and state excise. Despite reduced central funding, the state plans to invest in growth and welfare sectors. Total revenue receipts are projected at Rs 3,31,569 crore, with a revenue deficit of Rs 41,635 crore and a fiscal deficit of Rs 1,06,963 crore, maintaining debt sustainability within the prescribed limits.

11. ED summons CPI(M) MP Radhakrishnan in Karuvannur in PMLA case

Summary: The Enforcement Directorate has summoned a CPI(M) Member of Parliament for questioning on March 15 in connection with a money laundering case involving alleged irregularities at Karuvannur Service Cooperative Bank. The case, under the Prevention of Money Laundering Act, originated from multiple FIRs filed by the Kerala Police Crime Branch in 2021, concerning Rs 150 crore in irregularities. The ED alleges that the bank sanctioned bogus loans against the same property without members' knowledge, with funds being siphoned off and laundered. The CPI(M) denies the allegations, pledging to contest them legally and politically.


Notifications

Customs

1. 13/2025 - dated 13-3-2025 - Cus (NT)

Fixation of Tariff Value of Edible Oils, Brass Scrap, Areca Nut, Gold and Silver

Summary: The Central Board of Indirect Taxes & Customs has amended the tariff values for various goods under the Customs Act, 1962, effective March 14, 2025. The updated tariff values are specified for goods such as crude palm oil, RBD palm oil, crude palmolein, RBD palmolein, crude soybean oil, brass scrap, gold, and silver. Crude palm oil is set at $1169 per metric tonne, brass scrap at $5438 per metric tonne, gold at $941 per 10 grams, and silver at $1067 per kilogram. The tariff for areca nuts remains unchanged at $8140 per metric tonne.

GST

2. 10/2025 - dated 13-3-2025 - CGST

Seeks to amend Notification No. 02/2017-Central Tax, dated the 19th June, 2017

Summary: The Central Government has issued Notification No. 10/2025 to amend Notification No. 02/2017-Central Tax dated June 19, 2017, under the Central Goods and Services Tax Act, 2017. The amendments involve changes to the territorial jurisdictions for tax purposes in several districts across Rajasthan and Tamil Nadu. Specific districts in Alwar, Chennai Outer, Jaipur, Jodhpur, Madurai, Tiruchirappalli, and Udaipur have been redefined or expanded. This adjustment aims to streamline the administrative divisions for GST implementation in these regions.

SEBI

3. SEBI/LAD-NRO/GN/2025/235 - dated 11-3-2025 - SEBI

Securities and Exchange Board of India (Prohibition of Insider Trading) (Amendment) Regulations, 2025.

Summary: The Securities and Exchange Board of India (SEBI) has issued amendments to the Prohibition of Insider Trading Regulations, 2015, effective 90 days from publication. Key changes include the addition of several clauses to regulation 2, expanding the definition of unpublished price sensitive information to include events like changes in ratings, fraud, defaults, and regulatory actions. Regulation 3 now requires external information to be recorded within two days. Schedule B allows trading windows to remain open for certain external information. These amendments aim to enhance transparency and compliance within the securities market.


Highlights / Catch Notes

    GST

  • Anticipatory Bail Granted in GST Fraud Case Involving Fake Input Tax Credit to Multiple Taxpayers

    Case-Laws - HC : The HC granted anticipatory bail to the applicant implicated in a case involving fake input tax credit allegedly passed to 14 taxpayers including the applicant's firm. The court applied established principles for bail consideration, including: nature and gravity of accusations, applicant's antecedents, flight risk, and potential malicious intent behind the accusation. While acknowledging that detailed examination of evidence should be avoided at this stage, the court allowed the application. The applicant, upon arrest or appearance in connection with the FIR registered with DCB Police Station, Rajkot City, shall be released on bail upon furnishing a personal bond with one surety of like amount, subject to fulfillment of imposed conditions.

  • GST Registration Cannot Be Retrospectively Canceled Without Proper Notice and Evidence Under Section 29 of CGST Act

    Case-Laws - HC : The HC quashed the retrospective cancellation of GST registration under SS29 of CGST Act, 2017, finding procedural violations. Neither the SCN nor final order provided material evidence supporting the allegation under SS29(2)(e), nor did they notify the petitioner of intended retrospective cancellation. This procedural defect alone invalidated the action. The court clarified that authorities may continue proceedings regarding alleged fraudulent registration, provided the petitioner receives proper notice with supporting evidence. On time limitation, the court referenced Addichem Speciality LLP, confirming that condonation of delay depends on statutory provisions governing the remedy. The March 20, 2024 order was quashed insofar as it retrospectively canceled registration.

  • Court Sets Aside Order on Excess Input Tax Credit Claims, Directs 25% Deposit of Disputed Taxes Within Four Weeks

    Case-Laws - HC : The HC set aside the impugned order dated 07.03.2024 concerning excess Input Tax Credit (ITC) claimed due to non-reconciliation of information, including ITC from cancelled dealers, return defaulters, and tax non-payers. The Court directed the petitioner to deposit 25% of the disputed taxes determined in the impugned order within four weeks from receipt of the Court's order, as the petitioner had expressed willingness to pay this amount. Upon this condition being fulfilled, the impugned order was set aside and the petition was disposed of.

  • Stipend Payments Through Training Program Coordinator Qualify as "Pure Agent" Transactions Under Rule 33, Exempt from GST

    Case-Laws - AAR : The AAR ruled that the applicant, who coordinates on-the-job training programs between universities and industry partners, acts as a "pure agent" under Rule 33 regarding stipend payments to trainees. The applicant functions merely as a conduit, receiving stipend amounts from industry partners and disbursing them in full to trainees without deductions. The AAR determined that the applicant satisfies all conditions of a pure agent, as it merely facilitates the payment process while the actual service is supplied by trainees to the industry partners. Consequently, the stipend amounts received by the applicant from industry partners and paid in full to trainees do not attract GST liability.

  • Fish Finders Not Eligible for 5% Tax Rate as They Don't Qualify as Essential Vessel Parts Under N/N. 1/2017

    Case-Laws - AAR : The AAR ruled that fish finders cannot be classified as parts of vessels under Chapter headings 8901, 8902, 8904, 8905, 8906, or 8907, and therefore are not eligible for the reduced 5% tax rate under Sr.No.252 of N/N. 1/2017 Central Tax (Rate). The authority determined that while fish finders are manufactured for use on fishing vessels and other watercraft, vessels remain complete and functional without them. Unlike essential components integral to a vessel's operation, fish finders are auxiliary equipment. The AAR distinguished between classification cases under Central Excise Tariff and the present matter, which concerned whether the product constituted a vessel part for tax rate determination purposes.

  • Income Tax

  • Assessment Order Quashed: AO Improperly Consulted Superiors and Violated Natural Justice Under Section 143(3)

    Case-Laws - HC : The HC quashed an undated assessment order under s.143(3) of the Income Tax Act, finding multiple legal deficiencies. The AO improperly abdicated discretionary authority by consulting with superior officers who actively participated in drafting the assessment order rather than merely approving it as required by CBDT Circular. The court determined that principles of natural justice were violated as the petitioner was not afforded reasonable opportunity to present a defense. Additionally, the assessment order was deemed time-barred, as evidence showed it was not actually made by March 31, 2024, despite revenue authorities' claims. The HC rejected the revenue's "flimsy attempt" to retroactively establish timely issuance, declaring the order non est and legally unsustainable.

  • Banks Must Deduct TDS Under Section 194N on Government Subsidy Payments Despite Source of Funds

    Case-Laws - HC : The HC upheld the bank's obligation to deduct TDS under Section 194N on government subsidy payments made to the petitioners. The court determined that the bank must comply with mandatory tax deduction requirements regardless of the source of funds being government subsidies. While acknowledging that petitioners could receive refunds after assessment if no tax was ultimately payable, the court emphasized that Section 194N creates a mandatory obligation that cannot be circumvented. The HC referenced its previous ruling in a similar case which established that Section 194N mandates 2% deduction on cash withdrawals to promote a cashless economy, and notably cannot be avoided through the lower/nil deduction mechanism available under Section 197 for other provisions.

  • Double Deduction Claim Justifies Assessment Reopening Beyond Four-Year Limitation Under Section 147

    Case-Laws - HC : The HC upheld the reopening of assessment beyond the four-year limitation period, finding the appellant had claimed a deduction twice and failed to make full and true disclosure of material facts during original assessment proceedings. The AO correctly exercised jurisdiction under s. 147 after discovering the false claim. The court dismissed the writ appeal, noting that the appellant had already pursued alternate remedy by filing an appeal before the CIT(A) on the same issues after the writ petition's dismissal. The HC confirmed the appellant could address the merits of reopening before the CIT(A), rejecting the appellant's contention that no double claim existed.

  • Income Tax Reassessment Invalid When Disputed Amounts Were Already Reviewed During Original Assessment Under Section 143(1)

    Case-Laws - HC : The HC upheld the Appellate Tribunal's decision that reassessment under Section 147 was invalid. Although Explanation 1 to Section 147 states that mere production of evidence before the AO does not constitute disclosure under the first proviso, the disputed amounts (Rs. 594.33 lakhs and 438.96 lakhs) had been available and reviewed by the AO during the original assessment under Section 143(1). Therefore, invoking Section 148 for reassessment under Section 143(3) read with Section 147 lacked jurisdiction. The Court noted that while the assessee should have properly written off non-performing assets under Section 36(1)(vii), the substantial questions of law were resolved in the assessee's favor.

  • Agricultural Land Sale Proceeds: Section 148 Reassessment Notice Quashed as Mere Change of Opinion on Section 54B Deduction

    Case-Laws - HC : The HC quashed the reassessment notice issued under section 148, finding it impermissible as a mere change of opinion rather than based on new information. The authorities sought to reopen assessment regarding the taxpayer's section 54B deduction claim, despite having previously considered this issue during the original section 143(3) assessment. The court held that reopening requires "reasons to believe" with direct nexus to new tangible material, not merely alleging inadequate inquiry by the previous Assessing Officer. Since the taxpayer had fully disclosed all relevant documents during the original assessment, the reopening was invalid in law. Judgment favored the assessee.

  • Interest on GST, Late Filing Fees Allowed as Deduction Under Section 37; Higher Depreciation Rates Upheld for Mining Vehicles

    Case-Laws - AT : The ITAT ruled in favor of the assessee on multiple issues. Interest on GST and late filing fees was held to be allowable as a deduction under section 37, following Supreme Court precedent in Mahalakshmi Sugar Mills that interest paid to government for delayed payments cannot be characterized as a penalty. The Tribunal upheld higher depreciation rates of 30% on dumpers and tippers used for transportation in mining operations, finding the assessee had fulfilled necessary conditions for the enhanced rate. Similarly, the ITAT confirmed the CIT(A)'s decision allowing 40% depreciation on certain motor vehicles used for hire. Finally, the Tribunal deleted an addition under section 69C for alleged unexplained expenditure, as it was based solely on an unsigned Excel sheet recovered from a third party without corroborative evidence.

  • Assessment Order Void as Time-Barred Under Section 144C(13) When Issued Seven Months After DRP Directions

    Case-Laws - AT : The ITAT held that the final assessment order passed on 28.02.2023 was barred by limitation and therefore void. Per Section 144C(13), the Assessing Officer must pass the final order within one month from the end of the month in which DRP directions are received. In this case, DRP directions were received on 07.06.2022, making the deadline 31.07.2022. The TPO's effect order dated 14.07.2022 did not extend this limitation period. Additionally, the ITAT noted procedural irregularity as the draft assessment order was issued by the Faceless Assessment Centre while the final order was passed by the jurisdictional Assessing Officer, deviating from the faceless assessment system. Appeal decided in assessee's favor.

  • Penalty Under Section 271D Quashed as Time Limit Expired Despite TOLA Extension for Cash Loans Violating Section 269SS

    Case-Laws - AT : The ITAT quashed penalty proceedings under section 271D imposed on the assessee for accepting cash loans of Rs. 61,50,000/- in violation of section 269SS. The Tribunal held that the show cause notice dated 30.03.2021 required penalty order completion by 30.09.2021, which fell outside the Taxation and Other Laws Act (TOLA) period (20.03.2020 to 31.03.2021). Consequently, the CBDT notification dated 17.09.2021 did not extend the due date for passing the penalty order in this case. Following precedents in Mahesh Wood Products Pvt. Ltd. and Shri Subramaniam Thanu, the ITAT upheld the CIT(A)'s decision to quash the penalty order due to limitation issues.

  • PCIT Cannot Direct Penalty Under Section 270A Without AO's Finding of Under-Reported Income

    Case-Laws - AT : The ITAT quashed a revision order under s263 issued by the PCIT directing initiation of penalty proceedings under s270A for under-reported income. Following Chennai Metro Rail Ltd., the Tribunal held that the PCIT cannot invoke s263 without the AO first recording a finding regarding under-reporting of income under s270A(2). While the AO had initiated penalties under s271B and s271F, no determination of under-reported income was made. The PCIT improperly substituted his judgment for the AO's discretion, as the AO had deliberately chosen not to initiate s270A proceedings. The revision order was therefore invalid and the assessee's appeal was allowed.

  • Tribunal Eliminates Transfer Pricing Adjustments After Excluding Non-Comparable Companies Under Section 92C

    Case-Laws - AT : The ITAT ruled in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).

  • Fixed Deposits Linked to Shipping Operations: Interest Income Qualifies Under Tonnage Tax Scheme

    Case-Laws - AT : ITAT ruled that interest income from fixed deposits marked as lien, conditional deposits from public offerings, deposits placed to comply with facility agreements, and deposits for working capital requirements should be treated as part of profits from core shipping activities under the Tonnage Tax Scheme. The Tribunal determined these deposits were inextricably linked to the assessee's sole business of operating qualifying ships, making the interest business income rather than separate income. ITAT directed the AO to treat all interest income as part of profits from core shipping activities. Additionally, the Tribunal upheld CIT(A)'s deletion of disallowances under section 14A r.w. Rule 8D and administrative expenditure incurred toward earning income from incidental activities, following precedents from earlier decisions.

  • Payments to Foreign Entities: Technical Services or Reimbursements? AO Directed to Re-examine Taxability Under FTS Rules

    Case-Laws - AT : The ITAT remanded the case to the Assessing Officer for fresh examination on multiple issues. Regarding payments to foreign entities, the Tribunal held that further factual examination was necessary to determine whether the foreign entity made technical knowledge available to the assessee, qualifying as Fees for Technical Services/Included Services. The ITAT directed clarification on whether expenses constituted subcontracting or testing charges, as these terms carry different legal implications. The taxability of management fees was also remanded, with the assessee permitted to file documentary evidence supporting its alternative plea that payments were reimbursements of global costs. The Tribunal allowed the assessee's appeals for statistical purposes only, requiring the AO to conduct a comprehensive reassessment in accordance with law.

  • Title: Business Support Services Cost Allocations Without Profit Markup Not Taxable as Royalty Under India-UK DTAA

    Case-Laws - AT : The ITAT ruled that receipts from Business Support Services (BSS) should be deleted from the assessee's taxable income, following binding precedent established in the SIMPL case. The Tribunal determined that cost allocation for SUN Maintenance Software and GSAP maintenance charges cannot be treated as royalty under the India-UK DTAA, as these payments represented mere cost allocations without income elements. Similarly, expenses related to GSAP Go-Live and software access licenses were not royalties since they granted only the right to use copyrighted software, not rights to the copyright itself. The cost-to-cost basis of allocation across the group without profit markup further supported the non-taxable nature of these receipts in India.

  • Excel Sheet Found at Third Party's Premises Cannot Alone Justify Addition Under Section 69 for Unexplained Investments

    Case-Laws - AT : ITAT reversed the addition made by AO under section 69 for unexplained investment. The addition was based solely on an excel sheet found at a third party's premises, which allegedly showed cash loans advanced by the appellant. The Tribunal held that the excel sheet alone was insufficient evidence as it was neither authored by nor found in possession of the appellant. Without corroborative evidence establishing the appellant's connection to the alleged transactions, the addition was unsustainable. Following precedents in Appu Direct Pvt Ltd and Sant Lal, ITAT affirmed that liability cannot be fastened based solely on third-party materials without supporting evidence. The CIT(A)'s deletion of the addition was upheld.

  • Foreign Asset Disclosed in Revised Return by British Tax Resident: Penalty Under Black Money Act Section 43 Deleted

    Case-Laws - AT : The ITAT allowed the appellant's appeal, deleting the Rs. 10,00,000/- penalty imposed under Section 43 of the Black Money Act. The Tribunal found that the appellant, a British citizen who was only a tax resident in India for the relevant assessment year, had disclosed the foreign asset in a timely filed revised return. The revenue authorities failed to establish that the appellant was previously an Indian citizen or that the foreign investment involved undisclosed income from India. Relying on K Mohammad Haris and Rohit Krishna precedents, the ITAT concluded that the legislative intent of the Black Money Act was not applicable in this case, as there was proper disclosure within the prescribed time limit.

  • Customs

  • Tribunal Lacks Jurisdiction in Drawback Recovery Cases Under Section 129A(1) of Customs Act

    Case-Laws - AT : The CESTAT dismissed the appeal for lack of jurisdiction, holding that Section 129A(1) of the Customs Act, 1962, explicitly excludes the Tribunal's jurisdiction over matters relating to drawback under Chapter X. The statutory language contains a clear prohibition, twice emphasized in negative terms, that ousts the Tribunal's authority when Commissioner (Appeals) orders relate to drawback payments. The CESTAT followed binding precedent from the jurisdictional High Court which confirmed that "payment of drawback" in the proviso to Section 129A prevents the Tribunal from hearing cases involving drawback recovery. The concurrent jurisdiction between Revisionary Authority and the Tribunal in drawback matters was acknowledged as potentially perplexing for litigants.

  • Wind Operated Electricity Generator Towers Classified as WOEG Parts Under CTH 8503, Not General Structures

    Case-Laws - AT : CESTAT held that imported towers are parts of Wind Operated Electricity Generators (WOEG) properly classifiable under CTH 8503, not under CTI 7308 as general/civil structures. The Tribunal determined the Commissioner erred in mischaracterizing the towers as non-parts of Wind Energy Generators. CESTAT relied on precedent from CC Chennai v. Suzlon Towers and Structures Limited, where tower flanges were similarly classified under 8503 as WOEG parts. The Tribunal emphasized that the towers' specific function in wind energy generation qualified them for the tariff classification under 8503 and corresponding exemption benefits under Notification No.12/2012. The impugned order was set aside and the appeal allowed.

  • Lithium-ion batteries correctly classified under Schedule III, S. No. 376AA, attracting 18% IGST instead of 12%

    Case-Laws - AT : The CESTAT ruled that lithium-ion batteries are correctly classified under S. No. 376AA of Schedule III to Notification No. 01/2017-IT (Rate), as amended by Notification No. 19/2018-IT (Rate), attracting 18% IGST rather than 12%. The Tribunal applied the cardinal principle that when statutory language is plain and unambiguous, courts must give effect to the words as written without implication or intendment. However, the demand for interest was set aside following Bombay HC precedent in Mahindra & Mahindra Ltd. v. Union of India, which held that absent specific statutory provisions for interest levy under Section 3 of Customs Tariff Act, 1975 (prior to its amendment on August 16, 2024), such interest cannot be charged.

  • Customs Broker's License Revocation Modified: Penalty Upheld for Regulatory Violations Under Regulations 10(a) and 10(q)

    Case-Laws - AT : CESTAT partly allowed the appeal concerning a Customs Broker's license revocation. The Tribunal held that the appellant violated Regulations 10(a) by failing to produce client authorization when requested and 10(q) by not cooperating with investigations. However, the appellant did not violate Regulations 10(d) and 10(n), as customs brokers cannot be expected to verify the physical existence of exporters when government-issued documents are presumed genuine. Applying the doctrine of proportionality, CESTAT modified the order by setting aside the license revocation and security deposit forfeiture while upholding the Rs. 50,000 penalty, finding this sufficient to meet the ends of justice.

  • Confiscation of Gold Overturned: Revenue Failed to Prove Smuggling While Appellants Showed Melted Jewelry Evidence

    Case-Laws - AT : The CESTAT allowed an appeal against confiscation of 850.39 grams of gold seized from a person in a town seizure case. The tribunal held that Section 113 of the Customs Act was inapplicable as there were no allegations of attempted export. While statements recorded under Section 108 are admissible evidence, they cannot be treated as conclusive proof without scrutiny. The tribunal found that the Revenue failed to establish reasonable belief that the gold was smuggled, while the appellants successfully demonstrated that the irregular gold pieces were produced by melting old jewelry. The tribunal determined that absolute confiscation and penalties were unjustified under these circumstances.

  • FEMA

  • Denial of Cross-Examination Not a Natural Justice Violation When No Prejudice Demonstrated in FERA Proceedings

    Case-Laws - AT : The AT rejected appellant's contention that denial of cross-examination of departmental officers violated natural justice principles. The tribunal distinguished between proceedings under Customs Act and FERA, noting that appellants failed to demonstrate how cross-examination would have altered the case outcome or how its denial caused prejudice during adjudication. The AT determined that absence of cross-examination was not fatal to the proceedings and did not prejudice appellants' case. Consequently, the tribunal upheld the impugned interlocutory orders as maintainable and sustainable, finding no violation of natural justice principles in the Special Director's refusal to permit cross-examination of officers who recorded statements.

  • Corporate Law

  • Landlord Succeeds in Reclaiming Premises from Company in Liquidation Under Section 446 of Companies Act

    Case-Laws - HC : The HC granted the landlord's application under Section 446 of the Companies Act, directing the official liquidator to surrender premises leased to a company in liquidation. The Court determined it had jurisdiction to entertain such claims against companies in liquidation, rejecting the liquidator's argument that the landlord should pursue separate eviction proceedings. The Court found the liquidator's claim that the premises were needed for storing company records was disingenuous, as an Official Liquidator's Report had confirmed no books or records were present. The ex-directors' perfunctory applications for company revival were dismissed, with the Court concluding that continued rental payments were unjustified given the premises' disuse.

  • Bank's Loan Assignment to Ineligible Transferee Violates RBI Directives, Court Recalls Compromise Order

    Case-Laws - HC : The HC recalled its order approving a compromise between a bank and Savannah regarding the assignment of Shaila Clubs' loan. The Court determined the compromise was unlawful as it violated RBI Directives of 2021, which prohibit transfer of loan accounts to ineligible transferees. Savannah, not being a recognized transferee under RBI guidelines, could not legally acquire the loan. The Court rejected arguments regarding delay in filing the application for recall, holding that when a compromise is unlawful, technical grounds cannot prevent the Court from exercising its inherent power to recall orders. The Court restored the original petition, finding that allowing the unlawful compromise would frustrate RBI's regulatory objectives and improperly affect Shaila Clubs' rights without their consent.

  • SEBI's Relaxation of Reverse Book Building Valid in ICICI Securities Scheme of Arrangement Under Regulation 42

    Case-Laws - AT : The NCLAT dismissed an appeal challenging a scheme of arrangement between ICICI Bank and ICICI Securities. The Tribunal found that SEBI's relaxation from reverse book building requirements was within its regulatory powers under Regulation 42 of the Delisting Regulations. The valuation complied with Regulation 37(2)(j), meeting the minimum 60-day VWAP requirement. The court affirmed that valuation determinations should be left to accounting experts. ICICI Bank's shareholder outreach did not constitute undue influence, and disclosures in the explanatory statement were deemed sufficient. The appellant lacked standing to object under Section 230(4) of the Companies Act, 2013, and failed to demonstrate any procedural illegality or prejudice to public shareholders.

  • IBC

  • Operational Creditor's CIRP Application Rejected Due to Pre-existing Dispute Over Accounts Reconciliation

    Case-Laws - AT : NCLAT set aside the NCLT's order admitting the Corporate Debtor into CIRP. Though the application was filed within the limitation period (within three years of the last payment on 19.10.2016), the Tribunal found a pre-existing dispute evidenced by email exchanges regarding accounting differences. The Corporate Debtor had clearly stated in emails that no amount was payable to the Operational Creditor. Following precedents from the Supreme Court in S.S. Engineers and Sabarmati Gas Limited cases, which established that failure of reconciliation of accounts qualifies as a pre-existing dispute, the NCLAT concluded that NCLT erred in ignoring this dispute when admitting the Corporate Debtor into CIRP.

  • Appeal Dismissed: Challenging Liquidator Fee Determination Procedure Without Contesting SCC's Actual Decision Deemed Premature

    Case-Laws - AT : The NCLAT dismissed an appeal challenging procedural aspects of liquidator fee determination without contesting the Stakeholders' Consultation Committee's (SCC) actual decision on the matter. The Tribunal held that challenging the procedure without challenging the consequential decision rendered the appeal premature and untenable. The appellant had questioned the Adjudicating Authority's directive for the SCC to determine liquidator remuneration and incidental charges, but failed to challenge the SCC's subsequent decision dated 09.01.2025. The NCLAT concluded that no cause survived regarding the impugned order's directions, as the unchallenged SCC determination had already addressed the liquidator's fees and liquidation costs.

  • Delay in Re-filing Appeals Condoned but Recall Application Rejected After Resolution Plan Attained Finality Under IBC

    Case-Laws - AT : The NCLAT condoned the delay in re-filing appeals but ultimately dismissed the appellant's case. The Tribunal held that the appellant could not file a recall application alleging fraud after the resolution plan approval order dated 30.05.2022 had already been affirmed by the Appellate Court on 28.09.2022 and finalized by the Supreme Court on 11.03.2024 when the appellant withdrew their appeal under Section 62 of IBC. The NCLAT emphasized that once an order is affirmed through the appellate process, it attains finality, precluding subsequent recall applications regardless of when knowledge of alleged fraud was acquired. The dismissal of applications by the impugned order was found free from apparent error and did not warrant appellate interference.

  • Indian Laws

  • RBI's Failure to Exercise Regulatory Powers Under Chapter IIIB Can Be Challenged Through Writ of Mandamus

    Case-Laws - HC : The HC dismissed a letters patent appeal challenging maintainability of a writ petition against the RBI for failing to exercise regulatory powers under Chapter IIIB of the RBI Act regarding alleged fund misappropriation in ECL. The court affirmed that a writ of mandamus is maintainable where a public authority fails to exercise statutory powers, following CAG v. K.S. Jagannathan. The HC noted that despite RBI identifying violations by ECL in an email dated May 24, 2024, no action was taken. The court rejected arguments that NCLT proceedings barred the writ petition, clarifying that NCLT lacks jurisdiction to issue prerogative writs directing RBI to exercise powers under the RBI Act.

  • PMLA

  • Bail Denied in Money Laundering Case Under Section 3 of PMLA for Involvement in Mahadev Online Book Proceeds

    Case-Laws - HC : HC dismissed the bail application in a money laundering case related to proceeds from Mahadev online book. The court found sufficient prima facie evidence of the applicant's involvement in money laundering under Section 3 of PMLA, 2002. Rejecting the applicant's denial of knowledge about transactions, the court determined there were reasonable grounds to believe the accused was involved in an organized crime with complex facets. Under Section 45 of PMLA, the court concluded the applicant would likely commit further offenses if released. Given the nature of allegations, gravity of the offense, and investigation materials, bail was denied.

  • VAT

  • Taxpayer's Petition Dismissed for Concealing Material Facts About Revisional Proceedings in VAT Reassessment Challenge Under Section 36(1)

    Case-Laws - HC : The HC dismissed the writ petition on the principle of suppressio veri; suggestio falsi, as the petitioner failed to disclose material facts regarding suo-moto revisional proceedings while challenging a reassessment notice as time-barred under Section 36(1) of the TVAT Act, 2004. The petitioner neither mentioned the revisional proceedings nor challenged the revisional authority's order dated October 27, 2022, though it was referenced in the impugned notice. The court held that extraordinary relief under Article 226 cannot be granted to parties who suppress material facts, emphasizing that petitioners must approach writ courts with clean hands and full disclosure of all relevant information.

  • Service Tax

  • Notice Pay and Booking Cancellation Charges Not Subject to Service Tax Under Finance Act, 1994

    Case-Laws - AT : The CESTAT ruled that "notice pay" collected from employees for not serving agreed notice periods does not constitute consideration for service and is therefore not subject to service tax. Following precedents established in M/S Balaji Medical & Diagnostic Research Centre and Shiv Vilas Resort cases, the Tribunal determined that such amounts represent compensation related to employment rather than taxable services. Similarly, amounts retained by the appellant due to booking cancellations or customer no-shows were held not to constitute a "declared service" under Section 66E(e) of the Finance Act, 1994. The adjudicating authorities failed to follow judicial protocol by disregarding established precedents. Appeal allowed.


Case Laws:

  • GST

  • 2025 (3) TMI 734
  • 2025 (3) TMI 733
  • 2025 (3) TMI 732
  • 2025 (3) TMI 731
  • 2025 (3) TMI 730
  • 2025 (3) TMI 729
  • 2025 (3) TMI 728
  • Income Tax

  • 2025 (3) TMI 727
  • 2025 (3) TMI 726
  • 2025 (3) TMI 725
  • 2025 (3) TMI 724
  • 2025 (3) TMI 723
  • 2025 (3) TMI 722
  • 2025 (3) TMI 721
  • 2025 (3) TMI 720
  • 2025 (3) TMI 719
  • 2025 (3) TMI 718
  • 2025 (3) TMI 717
  • 2025 (3) TMI 716
  • 2025 (3) TMI 715
  • 2025 (3) TMI 714
  • 2025 (3) TMI 713
  • 2025 (3) TMI 712
  • 2025 (3) TMI 711
  • 2025 (3) TMI 710
  • 2025 (3) TMI 709
  • 2025 (3) TMI 708
  • 2025 (3) TMI 707
  • 2025 (3) TMI 706
  • 2025 (3) TMI 705
  • 2025 (3) TMI 704
  • 2025 (3) TMI 703
  • 2025 (3) TMI 702
  • 2025 (3) TMI 701
  • 2025 (3) TMI 700
  • Customs

  • 2025 (3) TMI 699
  • 2025 (3) TMI 698
  • 2025 (3) TMI 697
  • 2025 (3) TMI 696
  • 2025 (3) TMI 695
  • 2025 (3) TMI 694
  • 2025 (3) TMI 693
  • Corporate Laws

  • 2025 (3) TMI 692
  • 2025 (3) TMI 691
  • 2025 (3) TMI 690
  • Insolvency & Bankruptcy

  • 2025 (3) TMI 689
  • 2025 (3) TMI 688
  • 2025 (3) TMI 687
  • FEMA

  • 2025 (3) TMI 686
  • PMLA

  • 2025 (3) TMI 685
  • Service Tax

  • 2025 (3) TMI 684
  • 2025 (3) TMI 683
  • 2025 (3) TMI 682
  • 2025 (3) TMI 681
  • 2025 (3) TMI 680
  • 2025 (3) TMI 679
  • 2025 (3) TMI 678
  • Central Excise

  • 2025 (3) TMI 677
  • 2025 (3) TMI 676
  • 2025 (3) TMI 675
  • CST, VAT & Sales Tax

  • 2025 (3) TMI 674
  • 2025 (3) TMI 673
  • Indian Laws

  • 2025 (3) TMI 672
  • 2025 (3) TMI 671
 

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