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...
For assessment orders passed before 1 April 2025, the Assessing Officer lacked jurisdiction to impose or initiate penalty proceedings for contravention of cash loan or deposit restrictions under section 271D. Non-initiation of such penalty proceedings therefore could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision under section 263. A revisionary order founded solely on that omission was set aside, and the taxpayer's appeal was allowed.
For assessment orders passed before 1 April 2025, the Assessing Officer lacked jurisdiction to impose or initiate penalty proceedings for contravention of cash loan or deposit restrictions under section 271D. Non-initiation of such penalty proceedings therefore could not make the assessment order erroneous and prejudicial to the interests of the Revenue for revision under section 263. A revisionary order founded solely on that omission was set aside, and the taxpayer's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
