Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Rupee-denominated non-convertible debentures are treated as debt instruments for the concessional interest-tax treatment contemplated by section 194LD, because statutory definitions encompass interest on money borrowed, debt incurred, debentures and other securities. The bond-debenture distinction does not affect eligibility where the instruments are rupee denominated and the investor satisfies the prescribed foreign portfolio investor and other conditions. A separate claim under section 194LC requires express consideration: where an objection is left unaddressed in the final assessment, a denial attributable to that claim cannot be sustained.
Rupee-denominated non-convertible debentures are treated as debt instruments for the concessional interest-tax treatment contemplated by section 194LD, because statutory definitions encompass interest on money borrowed, debt incurred, debentures and other securities. The bond-debenture distinction does not affect eligibility where the instruments are rupee denominated and the investor satisfies the prescribed foreign portfolio investor and other conditions. A separate claim under section 194LC requires express consideration: where an objection is left unaddressed in the final assessment, a denial attributable to that claim cannot be sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
