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...
Notional rental income under Section 23(1)(a) is not chargeable on unsold flats during a period in which they are legally unoccupiable because no occupancy certificate has been issued. A completion certificate alone does not establish legal occupiability for this purpose. Consequently, notional rental income cannot form the basis for revision of an assessment for that period, and the Revenue's appeal was dismissed.
Notional rental income under Section 23(1)(a) is not chargeable on unsold flats during a period in which they are legally unoccupiable because no occupancy certificate has been issued. A completion certificate alone does not establish legal occupiability for this purpose. Consequently, notional rental income cannot form the basis for revision of an assessment for that period, and the Revenue's appeal was dismissed.
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TaxTMI 
TaxTMI 
of 4925 
