Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
ITAT quashed the reassessment proceedings initiated under s.147, finding the AO adopted a "blind approach" without proper appreciation of facts. The notice dated 31/03/2019 under s.148 and subsequent assessment order under s.143(3) read with s.147 were invalidated. The Tribunal upheld CIT(A)'s deletion of additions related to UK Film Tax Relief, noting these amounts had already been accounted for by EMIL in net realization figures. Regarding payments to Winford Production Ltd (UK), ITAT determined these were mere reimbursements of expenses for shooting arrangements and not fees for technical services under Indo-UK DTAA, as no technical knowledge was "made available" to the assessee. Consequently, no TDS obligation arose under s.195, and disallowance under s.40(a)(i) was deleted.
ITAT quashed the reassessment proceedings initiated under s.147, finding the AO adopted a "blind approach" without proper appreciation of facts. The notice dated 31/03/2019 under s.148 and subsequent assessment order under s.143(3) read with s.147 were invalidated. The Tribunal upheld CIT(A)'s deletion of additions related to UK Film Tax Relief, noting these amounts had already been accounted for by EMIL in net realization figures. Regarding payments to Winford Production Ltd (UK), ITAT determined these were mere reimbursements of expenses for shooting arrangements and not fees for technical services under Indo-UK DTAA, as no technical knowledge was "made available" to the assessee. Consequently, no TDS obligation arose under s.195, and disallowance under s.40(a)(i) was deleted.
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