Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
A related-party slump sale capital loss was disallowed because the assessee failed to prove genuineness, valuation basis and fair consideration through independent material, and the claimed loss was not supported beyond book entries. Compensation received on the departure of a key medical professional was taxed as revenue receipt because the hospital's profit-earning apparatus remained intact and the payment was linked to anticipated business loss rather than destruction of a capital source. The Tribunal also upheld deletion of interest disallowance and interest capitalisation additions on the footing that the assessee had sufficient own funds. Section 14A was held inapplicable because no exempt income was earned during the year.
A related-party slump sale capital loss was disallowed because the assessee failed to prove genuineness, valuation basis and fair consideration through independent material, and the claimed loss was not supported beyond book entries. Compensation received on the departure of a key medical professional was taxed as revenue receipt because the hospital's profit-earning apparatus remained intact and the payment was linked to anticipated business loss rather than destruction of a capital source. The Tribunal also upheld deletion of interest disallowance and interest capitalisation additions on the footing that the assessee had sufficient own funds. Section 14A was held inapplicable because no exempt income was earned during the year.
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