Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
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...
Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue interests. Tax was not required to be deducted on a back-to-back reimbursement of debenture interest paid through a fellow subsidiary because the intermediary did not receive income by way of interest; the revisionary authority neither disproved the supporting explanation nor established prejudice. Revision based on reconciled profit figures and ICDS adjustments was also unsustainable because the relevant details had been furnished and further verification was unnecessary. The revisionary order was quashed, the original assessment was restored, and the appeal was allowed.
Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue interests. Tax was not required to be deducted on a back-to-back reimbursement of debenture interest paid through a fellow subsidiary because the intermediary did not receive income by way of interest; the revisionary authority neither disproved the supporting explanation nor established prejudice. Revision based on reconciled profit figures and ICDS adjustments was also unsustainable because the relevant details had been furnished and further verification was unnecessary. The revisionary order was quashed, the original assessment was restored, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
