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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Section 115JB applied to the assessee because the statute does not require a company to be dividend-paying before book profit taxation can be invoked, and the Tribunal applied strict interpretation to reject exclusion on assumption or presumption. It also distinguished precedents cited for earlier assessment years and held that the amended provision effective from 01.04.2012 governed the matter, so the lower appellate view on MAT computation was affirmed. On MAT credit, the year being an abated assessment under section 153A left the assessment open to fresh computation on regular and incriminating material, so the assessee's claim was maintainable in principle and consequential relief was directed to be recomputed.
Section 115JB applied to the assessee because the statute does not require a company to be dividend-paying before book profit taxation can be invoked, and the Tribunal applied strict interpretation to reject exclusion on assumption or presumption. It also distinguished precedents cited for earlier assessment years and held that the amended provision effective from 01.04.2012 governed the matter, so the lower appellate view on MAT computation was affirmed. On MAT credit, the year being an abated assessment under section 153A left the assessment open to fresh computation on regular and incriminating material, so the assessee's claim was maintainable in principle and consequential relief was directed to be recomputed.
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