Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.
Revisionary jurisdiction cannot be invoked merely because a more extensive enquiry is preferred where the Assessing Officer has examined the deduction claim, obtained the statutory audit report and employee-wise details, issued a proposed disallowance notice, and considered the response. Revision requires an erroneous assessment that is prejudicial to Revenue, not simply an allegedly inadequate enquiry. Deduction eligibility is not denied solely because a staffing employer deploys workers at client premises, where it recruits, appoints, pays, reassigns and fulfils statutory employment obligations. Client supervision and salary reimbursement alone do not displace the employer-employee relationship. On these facts, revision for fresh examination was impermissible and the assessment was restored.
Note: It is a system-generated summary and is for quick reference only.