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...
Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.
Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.
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