Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
The assessee, a trust, claimed to be taxed at the same rate applicable to its beneficiary u/s 115BAA. However, this claim was dismissed as the assessee was not treated as a representative assessee. The CIT(A) accepted the assessee's status as a representative assessee and held that since the assessee is a determinate trust with RIIHL as its sole beneficiary and settler, and RIIHL has opted for taxation under the new regime at 22%, the assessee is also liable to be taxed at the same rate. The court held that u/s 161(1), a representative assessee shall be taxed in the same manner and to the same extent as the person represented. Since RIIHL was taxed u/s 115BAA, the assessee trust should also be taxed at the same rate. The court distinguished the case from Mrs. Amy F. Cama, where the trust was not considered a representative assessee. The Tribunal's decision in favor of the assessee was upheld.
The assessee, a trust, claimed to be taxed at the same rate applicable to its beneficiary u/s 115BAA. However, this claim was dismissed as the assessee was not treated as a representative assessee. The CIT(A) accepted the assessee's status as a representative assessee and held that since the assessee is a determinate trust with RIIHL as its sole beneficiary and settler, and RIIHL has opted for taxation under the new regime at 22%, the assessee is also liable to be taxed at the same rate. The court held that u/s 161(1), a representative assessee shall be taxed in the same manner and to the same extent as the person represented. Since RIIHL was taxed u/s 115BAA, the assessee trust should also be taxed at the same rate. The court distinguished the case from Mrs. Amy F. Cama, where the trust was not considered a representative assessee. The Tribunal's decision in favor of the assessee was upheld.
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