Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Insolvency moratorium does not shield company officers from cheque dishonour prosecution for liability arising before corporate insolvency proceedings...
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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