Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Taxable value of commercial training and coaching excludes separately supplied study material, hostel accommodation, mess facilities and ancillary collections lacking a nexus to coaching. Study material, treated as a distinct sale through separate invoicing and accounting, qualified for the pre-negative-regime exemption where no input credit was availed. Other fees require allocation by their actual nature, with non-taxable components excluded and unresolved allocations re-determined. Receivable entries alone did not establish unpaid tax, and the department had to prove that ancillary income arose from taxable service. Rental to a qualifying educational institution was exempt. Extended limitation failed absent suppression, and reasonable cause supported penalty relief. Service tax remained applicable only to tuition charges where applicable.
Taxable value of commercial training and coaching excludes separately supplied study material, hostel accommodation, mess facilities and ancillary collections lacking a nexus to coaching. Study material, treated as a distinct sale through separate invoicing and accounting, qualified for the pre-negative-regime exemption where no input credit was availed. Other fees require allocation by their actual nature, with non-taxable components excluded and unresolved allocations re-determined. Receivable entries alone did not establish unpaid tax, and the department had to prove that ancillary income arose from taxable service. Rental to a qualifying educational institution was exempt. Extended limitation failed absent suppression, and reasonable cause supported penalty relief. Service tax remained applicable only to tuition charges where applicable.
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