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...
Reassessment requires recorded material to have a rational connection and live nexus with the belief that income escaped assessment; suspicion based on statements or survey material unrelated to the taxpayer or investment transaction is insufficient. Allegations concerning an investor's representative, without transaction-specific material, could not support reopening for purportedly non-genuine share capital and share premium. For employees' provident fund and insurance contributions, the law prevailing when notice was issued allowed deduction where payment was made by the return-filing due date. A later contrary Supreme Court ruling could not retrospectively validate the recorded reason. The reassessment notice was quashed because neither ground established a sustainable reason to believe.
Reassessment requires recorded material to have a rational connection and live nexus with the belief that income escaped assessment; suspicion based on statements or survey material unrelated to the taxpayer or investment transaction is insufficient. Allegations concerning an investor's representative, without transaction-specific material, could not support reopening for purportedly non-genuine share capital and share premium. For employees' provident fund and insurance contributions, the law prevailing when notice was issued allowed deduction where payment was made by the return-filing due date. A later contrary Supreme Court ruling could not retrospectively validate the recorded reason. The reassessment notice was quashed because neither ground established a sustainable reason to believe.
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