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...
Year-end provisions for identified resident professional fees are treated as amounts on which tax must be deducted at source when the liability is created, so disallowance can arise if TDS is not deducted at that stage. Where deducted tax is deposited on or before the return-filing due date, the related expenditure is allowable for that year; if deposit is later, allowance shifts to the year of actual payment. Payments to offshore lawyers require examination of chargeability in India and any treaty protection before withholding is determined. A provision later reversed because the amount was not payable is treated as an unascertained liability and is not allowable.
Year-end provisions for identified resident professional fees are treated as amounts on which tax must be deducted at source when the liability is created, so disallowance can arise if TDS is not deducted at that stage. Where deducted tax is deposited on or before the return-filing due date, the related expenditure is allowable for that year; if deposit is later, allowance shifts to the year of actual payment. Payments to offshore lawyers require examination of chargeability in India and any treaty protection before withholding is determined. A provision later reversed because the amount was not payable is treated as an unascertained liability and is not allowable.
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