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...
The deductee-paid-tax exception applies to non-deduction of tax on External Development Charges where the payee has filed its return, included the relevant receipt in income, and paid the tax due. Verification of these statutory conditions is required before imposing liability for tax default and consequential interest. Liability for non-deduction and interest does not arise if the prescribed conditions are satisfied. The assessment was set aside and remanded for verification of the payee's compliance with those conditions.
The deductee-paid-tax exception applies to non-deduction of tax on External Development Charges where the payee has filed its return, included the relevant receipt in income, and paid the tax due. Verification of these statutory conditions is required before imposing liability for tax default and consequential interest. Liability for non-deduction and interest does not arise if the prescribed conditions are satisfied. The assessment was set aside and remanded for verification of the payee's compliance with those conditions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
