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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Addition u/s 56(2)(viib) - application of Rule 11UA - FMV of redeemable preference shares - sub-Rule (2) of Rule 11UA deals valuation in respect of unquoted equity shares only and does not refer to valuation of preference shares in any manner, whatsoever. The sub- Clause (c) of Rule 11UA(1), deals with the valuation of unquoted shares and securities other than equity shares which is based on a report from a merchant banker or an accountant. - AT
Addition u/s 56(2)(viib) - application of Rule 11UA - FMV of redeemable preference shares - sub-Rule (2) of Rule 11UA deals valuation in respect of unquoted equity shares only and does not refer to valuation of preference shares in any manner, whatsoever. The sub- Clause (c) of Rule 11UA(1), deals with the valuation of unquoted shares and securities other than equity shares which is based on a report from a merchant banker or an accountant. - AT
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