Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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TDS on leave fare concession payments was disputed where the assessee bank had treated the benefit as exempt, but employees had undertaken foreign-leg journeys. Although the substantive exemption under section 10(5) was found against the assessee, the Tribunal held that liability as an assessee in default could not be fastened for the relevant period because binding interim High Court directions governed deduction of tax on LFC payments. Non-deduction in compliance with those judicial orders did not attract the rigours of section 201(1) or consequential interest under section 201(1A), and the subsequent Supreme Court ruling could not retrospectively create that default. The demand and interest were deleted.
TDS on leave fare concession payments was disputed where the assessee bank had treated the benefit as exempt, but employees had undertaken foreign-leg journeys. Although the substantive exemption under section 10(5) was found against the assessee, the Tribunal held that liability as an assessee in default could not be fastened for the relevant period because binding interim High Court directions governed deduction of tax on LFC payments. Non-deduction in compliance with those judicial orders did not attract the rigours of section 201(1) or consequential interest under section 201(1A), and the subsequent Supreme Court ruling could not retrospectively create that default. The demand and interest were deleted.
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