Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Payments to medical consultants were held to be for independent professional services rather than salaried employment because consultancy agreements established a principaltoprincipal relationship. The consultants retained control over manner of service, and contractual supervision measures (fixed hours, reporting, leave rules, exclusivity clauses) did not convert a contract for service into a contract of service. Where consultants declared the income in their tax returns, the payer could not be treated as an assessee in default for TDS; the appeal by revenue was dismissed accordingly.
Payments to medical consultants were held to be for independent professional services rather than salaried employment because consultancy agreements established a principaltoprincipal relationship. The consultants retained control over manner of service, and contractual supervision measures (fixed hours, reporting, leave rules, exclusivity clauses) did not convert a contract for service into a contract of service. Where consultants declared the income in their tax returns, the payer could not be treated as an assessee in default for TDS; the appeal by revenue was dismissed accordingly.
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