Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Transfer pricing re-characterisation of redeemable preference share subscription and redemption as loans was rejected because earlier decisions in the assessee's own case had already held that, absent material showing sham or concealment of the real character, the TPO could not disregard the apparent transaction or impute notional interest. The interest disallowance on advances to sister concerns also failed because the Tribunal found sufficient own funds on the balance sheets, giving rise to a presumption that the advances came from those funds; that factual finding was not shown to be perverse. Both appeals were dismissed.
Transfer pricing re-characterisation of redeemable preference share subscription and redemption as loans was rejected because earlier decisions in the assessee's own case had already held that, absent material showing sham or concealment of the real character, the TPO could not disregard the apparent transaction or impute notional interest. The interest disallowance on advances to sister concerns also failed because the Tribunal found sufficient own funds on the balance sheets, giving rise to a presumption that the advances came from those funds; that factual finding was not shown to be perverse. Both appeals were dismissed.
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