Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Penalty under Section 271(1)(c) does not follow merely from a Section 43B disallowance where statutory tax liabilities were not claimed as expenditure, were disclosed in the tax audit report, and rested on a plausible interpretation; a quantum addition alone does not establish inaccurate particulars. Foreign dividend income disclosed in Schedule SI and taxed at the applicable special rate is not concealed merely because it was omitted from the computation summary, where the mismatch was inadvertent and rectification was voluntarily sought before revisionary proceedings. Penalties relating to both items were deleted, and the Revenue's challenge failed.
Penalty under Section 271(1)(c) does not follow merely from a Section 43B disallowance where statutory tax liabilities were not claimed as expenditure, were disclosed in the tax audit report, and rested on a plausible interpretation; a quantum addition alone does not establish inaccurate particulars. Foreign dividend income disclosed in Schedule SI and taxed at the applicable special rate is not concealed merely because it was omitted from the computation summary, where the mismatch was inadvertent and rectification was voluntarily sought before revisionary proceedings. Penalties relating to both items were deleted, and the Revenue's challenge failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4931 
