Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
Petitioner's revenue from an Indian payer was not subjected to tax deduction at source, despite being taxable income in India. The assessing officer reopened assessment u/s 147, contending the live feed component was taxable as royalty and rejecting the 95:5 bifurcation of license fee between live feed and recorded content. Following the Delhi High Court's decision in CIT v. Fox Network Group, the court found no justification for the reassessment action. The assessing officer's view rejecting the 95:5 bifurcation was rendered perverse in light of the agreement's stipulations. Consequently, the court allowed the writ petitions and quashed the order u/s 148A(d).
Petitioner's revenue from an Indian payer was not subjected to tax deduction at source, despite being taxable income in India. The assessing officer reopened assessment u/s 147, contending the live feed component was taxable as royalty and rejecting the 95:5 bifurcation of license fee between live feed and recorded content. Following the Delhi High Court's decision in CIT v. Fox Network Group, the court found no justification for the reassessment action. The assessing officer's view rejecting the 95:5 bifurcation was rendered perverse in light of the agreement's stipulations. Consequently, the court allowed the writ petitions and quashed the order u/s 148A(d).
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