Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
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