Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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Exemption u/s 10(26) - Exemption to individual members of Scheduled Tribes - Whether a partnership firm, formed by individual partners who are entitled to an exemption u/s 10(26), can claim the same exemption. - The tribunal observed that under the Income Tax Act, a partnership firm is treated as a separate and distinct entity from its partners. The Act expressly includes firms in the definition of "person" for the purpose of tax assessment, making them separately assessable entities. - The exemption u/s 10(26) of the Income Tax Act, specifically granted to individual members of Scheduled Tribes, cannot be extended to partnership firms, even if they are solely constituted of such individuals.
Exemption u/s 10(26) - Exemption to individual members of Scheduled Tribes - Whether a partnership firm, formed by individual partners who are entitled to an exemption u/s 10(26), can claim the same exemption. - The tribunal observed that under the Income Tax Act, a partnership firm is treated as a separate and distinct entity from its partners. The Act expressly includes firms in the definition of "person" for the purpose of tax assessment, making them separately assessable entities. - The exemption u/s 10(26) of the Income Tax Act, specifically granted to individual members of Scheduled Tribes, cannot be extended to partnership firms, even if they are solely constituted of such individuals.
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