Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
One-time settlement paid to contractors was treated as revenue business expenditure incurred wholly and exclusively for business purposes; the Tribunal accepted that the contractors remained responsible for their workers, tax was deducted at source, and the payments were made to avoid disruption during restructuring, so the full deduction was allowed and the four-fifths disallowance deleted. The disallowance linked to exempt income was remitted because the Assessing Officer proceeded on the mistaken assumption that no suo motu disallowance existed, while the assessee had not fully supported its computation, requiring fresh examination after considering the computation and further material. The treaty-rate claim on dividend distribution tax was admitted as a pure legal ground and remitted for decision after the Supreme Court's final ruling on the controversy.
One-time settlement paid to contractors was treated as revenue business expenditure incurred wholly and exclusively for business purposes; the Tribunal accepted that the contractors remained responsible for their workers, tax was deducted at source, and the payments were made to avoid disruption during restructuring, so the full deduction was allowed and the four-fifths disallowance deleted. The disallowance linked to exempt income was remitted because the Assessing Officer proceeded on the mistaken assumption that no suo motu disallowance existed, while the assessee had not fully supported its computation, requiring fresh examination after considering the computation and further material. The treaty-rate claim on dividend distribution tax was admitted as a pure legal ground and remitted for decision after the Supreme Court's final ruling on the controversy.
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