Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
Safe harbour under Rule 11UA(4) was treated as curative and retrospectively applicable: where the difference between issue price and the prescribed valuation did not exceed 10%, the issue price was deemed to be fair market value, so the section 56(2)(viib) addition on shares issued to the resident shareholder could not survive. Legal and professional charges for due diligence, business evaluation and advisory services connected with structuring and growth were held to be revenue expenditure, because no capital asset or enduring capital advantage was shown; the disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
