Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
A single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.
A single show-cause notice or composite assessment order cannot cover multiple tax periods where separate year-wise proceedings are required under Sections 73 and 74. The notes state that an assessment covering 2017-18 and 2018-19 was therefore set aside, with liberty to commence fresh proceedings separately for each financial year, subject to the deposit condition and exclusion of time for limitation. They also record that a writ challenge to the original assessment remains maintainable despite dismissal of an appeal, so the appellate dismissal did not prevent examination of the assessment's legality. The matter was consequently remitted on the limited ground of the composite assessment.
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TaxTMI 
TaxTMI 
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