Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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