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 ...
Section 153C proceedings against a person other than the searched person require a satisfaction note as a precondition. Where the searched person's assessment has concluded, the satisfaction note must be recorded immediately thereafter; a delay exceeding four years does not meet that requirement. Proceedings initiated for Assessment Year 2017-18 on the basis of such delayed recording were invalidated, and the related notice, consequential order and demand notice were quashed.
Section 153C proceedings against a person other than the searched person require a satisfaction note as a precondition. Where the searched person's assessment has concluded, the satisfaction note must be recorded immediately thereafter; a delay exceeding four years does not meet that requirement. Proceedings initiated for Assessment Year 2017-18 on the basis of such delayed recording were invalidated, and the related notice, consequential order and demand notice were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
