Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Income assessed in hands of Appellant as Representative Assessee. No credit for prepaid taxes availed by beneficiaries. JCIT(A) directed AO to verify claim of prepaid taxes in beneficiaries' hands. Interest levied. Return filed by assessee as representative assessee. Tax position for onshore AIF funds. Assessee registered as AIF, representative of beneficiaries. CPC didn't consider advance tax paid by trustee. Assessee furnished income statement to beneficiaries indicating income share and taxes paid. Trustee paid tax on beneficiaries' income share under their PANs, gave declaration. TDS by investees under beneficiaries' PAN, advance tax paid by assessee for first quarter. Declaration withdrawn following CBDT Circular clarifying tax position for onshore AIFs. Assessee eligible for pass-through taxation. Assessee allowed credit for TDS and advance tax claimed in return as representative assessee. CIT(A) findings upheld, assessee's appeal dismissed.
Income assessed in hands of Appellant as Representative Assessee. No credit for prepaid taxes availed by beneficiaries. JCIT(A) directed AO to verify claim of prepaid taxes in beneficiaries' hands. Interest levied. Return filed by assessee as representative assessee. Tax position for onshore AIF funds. Assessee registered as AIF, representative of beneficiaries. CPC didn't consider advance tax paid by trustee. Assessee furnished income statement to beneficiaries indicating income share and taxes paid. Trustee paid tax on beneficiaries' income share under their PANs, gave declaration. TDS by investees under beneficiaries' PAN, advance tax paid by assessee for first quarter. Declaration withdrawn following CBDT Circular clarifying tax position for onshore AIFs. Assessee eligible for pass-through taxation. Assessee allowed credit for TDS and advance tax claimed in return as representative assessee. CIT(A) findings upheld, assessee's appeal dismissed.
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