Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question of fact - CIT directed to determine income on account of receipts from provision of software enabled solutions to the oil and gas industry along with providing annual maintenance services of the software - CIT to assess the Petitioner’s income and tax payable thereon by first determining the nature of the income/receipts in the hands of the assessee in light of the observations made in this judgment. - HC
Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question of fact - CIT directed to determine income on account of receipts from provision of software enabled solutions to the oil and gas industry along with providing annual maintenance services of the software - CIT to assess the Petitioner’s income and tax payable thereon by first determining the nature of the income/receipts in the hands of the assessee in light of the observations made in this judgment. - HC
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