Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Receipts from feeder vessels and slot-hire arrangements were held to have a direct and integral nexus with the assessee's shipping business in international traffic, so they fell within Article 8 of the India-Germany DTAA and could not be separately taxed under section 44B; the addition on those receipts was deleted. The Tribunal did not decide the short TDS credit claim on merits and remitted it to the Assessing Officer for factual verification against the income offered and corresponding tax deducted, with a fresh decision after hearing the assessee.
Receipts from feeder vessels and slot-hire arrangements were held to have a direct and integral nexus with the assessee's shipping business in international traffic, so they fell within Article 8 of the India-Germany DTAA and could not be separately taxed under section 44B; the addition on those receipts was deleted. The Tribunal did not decide the short TDS credit claim on merits and remitted it to the Assessing Officer for factual verification against the income offered and corresponding tax deducted, with a fresh decision after hearing the assessee.
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