Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
HC invalidated CBDT Circular No. 07/2007's paragraph 9 as ultra vires, ruling it exceeded powers under Section 119. Court found refund applications for excess tax deducted under Section 195 were wrongly rejected on limitation grounds. Following S.A. Builders precedent on commercial expediency, HC determined that borrowings through FCCBs and ECBs used for overseas holding company qualified as debt incurred for earning foreign income. The expenditure met commercial expediency test as investments were motivated by expectation of foreign source income. Court directed refund of excess taxes deposited for FY 2010-11 to 2012-13, rejecting revenue's interpretation of Section 9(1)(v)(b) as unsustainable.
HC invalidated CBDT Circular No. 07/2007's paragraph 9 as ultra vires, ruling it exceeded powers under Section 119. Court found refund applications for excess tax deducted under Section 195 were wrongly rejected on limitation grounds. Following S.A. Builders precedent on commercial expediency, HC determined that borrowings through FCCBs and ECBs used for overseas holding company qualified as debt incurred for earning foreign income. The expenditure met commercial expediency test as investments were motivated by expectation of foreign source income. Court directed refund of excess taxes deposited for FY 2010-11 to 2012-13, rejecting revenue's interpretation of Section 9(1)(v)(b) as unsustainable.
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