Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Year-end estimated expenditure provisions, where invoices, precise liabilities and payees remain unascertained, do not amount to credit of an ascertainable sum to an identified payee under the mercantile system. Tax-deduction obligations therefore arise only when liabilities crystallise, with tax deducted where applicable upon receipt of invoices; reversal of the provisions in the succeeding year supports that treatment. A demand for tax-deduction default cannot be sustained merely on creation of such provisions. Further, where the same non-deduction has already led to disallowance of expenditure, it cannot also support a tax-deduction default demand; consequential interest fails with the principal demand.
Year-end estimated expenditure provisions, where invoices, precise liabilities and payees remain unascertained, do not amount to credit of an ascertainable sum to an identified payee under the mercantile system. Tax-deduction obligations therefore arise only when liabilities crystallise, with tax deducted where applicable upon receipt of invoices; reversal of the provisions in the succeeding year supports that treatment. A demand for tax-deduction default cannot be sustained merely on creation of such provisions. Further, where the same non-deduction has already led to disallowance of expenditure, it cannot also support a tax-deduction default demand; consequential interest fails with the principal demand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
