Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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