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...
A timely filed rectification application remains capable of decision on merits after the three-month disposal timeline expires. The requirement that the competent authority decide the application "as far as possible" within that period is directory: it requires an endeavour to comply but neither makes the authority functus officio nor removes its jurisdiction after three months. Rejection solely on the ground that the disposal period had expired was quashed, and the application was remitted for a merits-based decision within three months.
A timely filed rectification application remains capable of decision on merits after the three-month disposal timeline expires. The requirement that the competent authority decide the application "as far as possible" within that period is directory: it requires an endeavour to comply but neither makes the authority functus officio nor removes its jurisdiction after three months. Rejection solely on the ground that the disposal period had expired was quashed, and the application was remitted for a merits-based decision within three months.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
