Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Filters / Advanced Search ❯
TEXT

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
☰   Show Results ❯
    Proportionality in Customs Broker licence revocation protects brokers where employee misconduct lacks deliberate broker involvement or repeated violat...
    Essential character determines classification of multifunctional car radio units and qualifying SKD kits as automotive radio receivers.
    Reasoned SFIO investigation orders require discernible statutory grounds; later material cannot cure a defective initiation.
    Financial debt requires time value of money; share-purchase consideration without a repayment obligation cannot support insolvency proceedings.
    Pre-existing quality disputes restrict insolvency admission where credible contemporaneous evidence requires fuller determination in appropriate proce...
    Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
    Reasoned FEMA penalty orders must disclose evidence supporting liability; an unexplained affirmance requires fresh adjudication.
    Retrospective industrial incentive withdrawal invalidated; deemed Priority Sector approval and clinker-based cement SGST reimbursement eligibility rem...
    Cheque signature presumptions withstand uncorroborated lost-cheque claims, while proprietary concern liabilities remain personal to the proprietor.
    Cheque execution presumption: admitted signatures shift the burden, and a refer-to-drawer return supports dishonour liability.
    Personal GST penalty extends beyond registration only when benefit retention and transaction control are cumulatively proved.
    Proof of tenancy rights determines whether insolvency professionals can recover corporate-debtor premises from permissive occupants.
    GST portal service requires statutory validity and meaningful access before ex parte demand proceedings can withstand challenge.
    TNMM comparability requires symmetrical operating-cost treatment and FAR-based review, while search matrices cannot replace substantiated functional a...
    Reasonable belief must precede gold seizure; without recorded objective grounds, the reverse burden for smuggling does not arise.
    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...
    Unstayed Tribunal Orders Preserve Corporate Authority Despite Pending Oppression Appeals and Limit Bank Intervention in Account Operations
    Will-based benami claims remain barred where pleadings assert beneficial ownership and no statutory fiduciary relationship exists.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Back

All Highlights

Amounts received/paid between the taxpayer and group companies...

Group-company timeshare week purchases and sales: treated as commercial deals, not s.2(22)(e) loans; additions and invalid assessment struck down.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Income Tax December 23, 2025 Case Laws AT
Amounts received/paid between the taxpayer and group companies for purchase/sale of timeshare weeks were held to be commercial transactions, supported by consideration and indirect tax payment, and therefore not "loans or advances" attracting deemed dividend under s. 2(22)(e); the addition was deleted and the revenue's ground failed. Commission expenditure was allowed since the taxpayer furnished adequate particulars and there was no evidence of cash-back or off-book payments; disallowance merely for non-confirmation by parties was rejected and the revenue's ground failed. Depreciation on capitalised timeshare weeks was sustained as forming part of the building block/cost of improvement, consistently accepted in later years; the revenue's ground failed. Ad hoc disallowance of foreign travel was set aside for lack of basis, and the revenue's ground failed. An assessment framed on a non-existing amalgamated entity was held void for lack of jurisdiction, not curable under s. 292B, and was set aside. - ITAT

Topics

Acts Income Tax