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 ...
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
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TaxTMI 
TaxTMI 
of 4884 
