Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
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TaxTMI 
TaxTMI 
of 4878 
