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 ...
Appellate authorities must decide appeals on their merits and address the grounds raised, even where the assessee does not participate after notice. Ex parte disposal may rest on the material on record, but summary dismissal for non-prosecution without a reasoned, speaking adjudication is impermissible. Appellate orders concerning assessment and penalty matters for three assessment years were set aside for fresh disposal after reasonable hearing opportunity. A filing delay caused by failure to serve an appellate order through the physical mode requested by the assessee warranted condonation under a justice-oriented, liberal approach.
Appellate authorities must decide appeals on their merits and address the grounds raised, even where the assessee does not participate after notice. Ex parte disposal may rest on the material on record, but summary dismissal for non-prosecution without a reasoned, speaking adjudication is impermissible. Appellate orders concerning assessment and penalty matters for three assessment years were set aside for fresh disposal after reasonable hearing opportunity. A filing delay caused by failure to serve an appellate order through the physical mode requested by the assessee warranted condonation under a justice-oriented, liberal approach.
Note: It is a system-generated summary and is for quick reference only.