Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Search-assessment limitation requires court-ordered stay periods to be excluded within the single composite limitation period before testing whether TOLA extends that date. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge the period available for completing assessments. For years affected by the stay, the composite limitation date fell outside the TOLA window; for the remaining years, the extension operated only until 30 September 2021. The assessments, related notices and consequential penalty proceedings for all nine assessment years were time-barred and quashed, while the merits of the additions remained open.
Search-assessment limitation requires court-ordered stay periods to be excluded within the single composite limitation period before testing whether TOLA extends that date. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge the period available for completing assessments. For years affected by the stay, the composite limitation date fell outside the TOLA window; for the remaining years, the extension operated only until 30 September 2021. The assessments, related notices and consequential penalty proceedings for all nine assessment years were time-barred and quashed, while the merits of the additions remained open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
