Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Rejection of a compounding application filed beyond the prescribed time limit as per the CBDT circular. The High Court held that the CBDT cannot issue a circular contrary to the object of the provisions, and fixing a time limit for filing a compounding application is not permissible u/s 279(2) of the Income Tax Act. The Court ruled that once an offence is compoundable by law, its compoundability cannot be restricted by imposing a time limit. The impugned order was set aside, and the matter was remanded to the respondent to consider the compounding application on record, as the petitioner was not a habitual offender.
Rejection of a compounding application filed beyond the prescribed time limit as per the CBDT circular. The High Court held that the CBDT cannot issue a circular contrary to the object of the provisions, and fixing a time limit for filing a compounding application is not permissible u/s 279(2) of the Income Tax Act. The Court ruled that once an offence is compoundable by law, its compoundability cannot be restricted by imposing a time limit. The impugned order was set aside, and the matter was remanded to the respondent to consider the compounding application on record, as the petitioner was not a habitual offender.
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