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 ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Discretion to condone delay in filing a revised return may be exercised where revisions to tax-reporting information result in the same interest income being taxed in two assessment years. Genuine hardship must be assessed from the surrounding facts rather than a fixed formula. Double taxation, prompt pursuit of rectification remedies and absence of taxpayer inaction supported relief, while refusal would result in unjust enrichment. Permission to file the revised return was granted, subject to verification of the relevant facts and an appropriate decision in accordance with law.
Discretion to condone delay in filing a revised return may be exercised where revisions to tax-reporting information result in the same interest income being taxed in two assessment years. Genuine hardship must be assessed from the surrounding facts rather than a fixed formula. Double taxation, prompt pursuit of rectification remedies and absence of taxpayer inaction supported relief, while refusal would result in unjust enrichment. Permission to file the revised return was granted, subject to verification of the relevant facts and an appropriate decision in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
