Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed.
Rectification without enhancement was upheld where the appellate authority only restored omitted lines to its existing reasoning and made no fresh addition or increase in liability; in that situation, fresh notice to the assessee was not required, and a pending appeal did not bar rectification before final hearing. On merits, commission paid to a Sweden-based agent for procuring export orders and following up payments was held to be commission, not fees for technical or consultancy services, because the emails showed order specifications and buyer requirements rather than technical advice. As the services were rendered outside India, the payment was not taxable in India, no tax deduction obligation arose, and the disallowance for non-deduction of tax failed.
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