Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
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...
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Penalty imposed u/s 271(1)(c) - satisfaction relates to Section 271AAA - satisfaction of the AO qua a wrong section for the purposes of penalty of strict nature is clearly no satisfaction in the eyes of law. The whole action of the AO carried under s. 271(1)(c) is thus vitiated and a nullity in law.
Penalty imposed u/s 271(1)(c) - satisfaction relates to Section 271AAA - satisfaction of the AO qua a wrong section for the purposes of penalty of strict nature is clearly no satisfaction in the eyes of law. The whole action of the AO carried under s. 271(1)(c) is thus vitiated and a nullity in law.
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