Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Article 289(1) immunises the property and income of a State from Union taxation, overriding an inconsistent charge under the Income-tax Act. A State-controlled conservation society, governed and staffed by State functionaries, financially and functionally dependent on the State, and discharging environmental conservation obligations linked to Article 48A, falls within State instrumentality principles. Statutory, ring-fenced conservation funds and incidental interest constitute public funds held in trust rather than ordinary commercial receipts. Such income cannot be charged to tax, and tax-recovery action lacks jurisdiction. Bank-account attachment for recovery under the Income-tax Act was therefore unsustainable and quashed.
Article 289(1) immunises the property and income of a State from Union taxation, overriding an inconsistent charge under the Income-tax Act. A State-controlled conservation society, governed and staffed by State functionaries, financially and functionally dependent on the State, and discharging environmental conservation obligations linked to Article 48A, falls within State instrumentality principles. Statutory, ring-fenced conservation funds and incidental interest constitute public funds held in trust rather than ordinary commercial receipts. Such income cannot be charged to tax, and tax-recovery action lacks jurisdiction. Bank-account attachment for recovery under the Income-tax Act was therefore unsustainable and quashed.
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