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...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Priority under section 26E of the Securitisation Act favours a bank's registered security interest over an Income Tax attachment where the Department has not publicly proclaimed the attachment in the prescribed manner or registered its claim or attachment order with CERSAI. A prior attachment alone does not displace the secured creditor's statutory priority. The attachment and resulting encumbrance must be removed to the extent they obstruct recovery of the bank's secured dues, while the Income Tax Department may recover its dues from surplus sale proceeds or other assets in accordance with law.
Priority under section 26E of the Securitisation Act favours a bank's registered security interest over an Income Tax attachment where the Department has not publicly proclaimed the attachment in the prescribed manner or registered its claim or attachment order with CERSAI. A prior attachment alone does not displace the secured creditor's statutory priority. The attachment and resulting encumbrance must be removed to the extent they obstruct recovery of the bank's secured dues, while the Income Tax Department may recover its dues from surplus sale proceeds or other assets in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
