Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
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...
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
