Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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