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...
Customs-duty refund limitation for provisionally assessed duty runs from communication of the final assessment order to the person entitled to claim refund, rather than from the order's date. A limitation period cannot begin before the claimant has actual or constructive knowledge of the order creating the remedy. Revenue must establish service through the prescribed statutory mode; mere despatch without proof of delivery is insufficient. In the absence of Revenue evidence of despatch or delivery, and with unrebutted postal evidence of receipt, the refund claim was treated as filed within the one-year period and remained eligible for consideration.
Customs-duty refund limitation for provisionally assessed duty runs from communication of the final assessment order to the person entitled to claim refund, rather than from the order's date. A limitation period cannot begin before the claimant has actual or constructive knowledge of the order creating the remedy. Revenue must establish service through the prescribed statutory mode; mere despatch without proof of delivery is insufficient. In the absence of Revenue evidence of despatch or delivery, and with unrebutted postal evidence of receipt, the refund claim was treated as filed within the one-year period and remained eligible for consideration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
