Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Section 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
Section 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
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