Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Taxability of interest under a flat buy-back arrangement turns on the actual repayment sequence and the income credited in the assessee's hands. Where documents, including the payer's email and remand material, showed that principal was to be repaid first and premium or interest only thereafter, the Assessing Officer could not treat the outstanding balance as interest already received or accrued without evidence that the full premium component had been paid. TDS credit was also noted as admissible only when the corresponding income is offered to tax, and the disputed addition was deleted.
Taxability of interest under a flat buy-back arrangement turns on the actual repayment sequence and the income credited in the assessee's hands. Where documents, including the payer's email and remand material, showed that principal was to be repaid first and premium or interest only thereafter, the Assessing Officer could not treat the outstanding balance as interest already received or accrued without evidence that the full premium component had been paid. TDS credit was also noted as admissible only when the corresponding income is offered to tax, and the disputed addition was deleted.
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