Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
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TaxTMI 
TaxTMI 
of 4921 
