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...
Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.
Concurrent factual findings on cash credits recorded in an impounded diary did not give rise to a substantial question of law in the income-tax appeals. The credits recorded in a partner's name were treated as unaccounted funds introduced by the partner into the partnership firm after considering the stated unaccounted sources. A plea to assess the entire diary amount in the partner's hands required reconsideration of those factual findings rather than resolution of a legal issue. The challenges therefore failed for want of a substantial question of law.
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