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...
Limited-scrutiny assessment confines the Assessing Officer's inquiry to issues selected for scrutiny unless the prescribed procedure converts it into complete scrutiny. Where scrutiny concerned high liabilities relative to income and agricultural income, loss on sale of assets lacked a nexus to those issues, and no conversion was shown. The deeming rule for inadequate inquiry or verification applies only to matters within the lawful assessment scope. Consequently, failure to examine the asset-sale loss did not render the assessment erroneous and prejudicial to Revenue; the revisional order was set aside and the assessment restored.
Limited-scrutiny assessment confines the Assessing Officer's inquiry to issues selected for scrutiny unless the prescribed procedure converts it into complete scrutiny. Where scrutiny concerned high liabilities relative to income and agricultural income, loss on sale of assets lacked a nexus to those issues, and no conversion was shown. The deeming rule for inadequate inquiry or verification applies only to matters within the lawful assessment scope. Consequently, failure to examine the asset-sale loss did not render the assessment erroneous and prejudicial to Revenue; the revisional order was set aside and the assessment restored.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4927 
