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 ...
Section 167B, which applies the maximum marginal rate where beneficiaries' shares are indeterminate, does not apply to public charitable trusts or organisations. Their income is chargeable at normal rates notwithstanding uncertainty regarding beneficiaries' shares. Application of this principle requires verification of the trust deed, rectification application, return of income and original assessment order. Following verification, the tax liability should be computed at normal rates and consequential relief granted where due.
Section 167B, which applies the maximum marginal rate where beneficiaries' shares are indeterminate, does not apply to public charitable trusts or organisations. Their income is chargeable at normal rates notwithstanding uncertainty regarding beneficiaries' shares. Application of this principle requires verification of the trust deed, rectification application, return of income and original assessment order. Following verification, the tax liability should be computed at normal rates and consequential relief granted where due.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
