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...
Liquidated damages, underwriting commission and structuring fees were treated as interest for exemption under section 10(23G): liquidated damages were covered by the court's earlier ruling, underwriting commission fell within the Explanation to section 10(23G) as commission for extending a guarantee or enhancing credit, and structuring fees were included within the expanded definition of interest in section 2(28A) as service fee or other charge connected with borrowed money. On deductions, the court held that sections 36(1)(viia)(c) and 36(1)(viii) operate independently, so deduction under one provision cannot be deferred until the other is exhausted; the amendment to section 36(1)(viii) affected only computation. The questions addressed were answered in favour of the assessee.
Liquidated damages, underwriting commission and structuring fees were treated as interest for exemption under section 10(23G): liquidated damages were covered by the court's earlier ruling, underwriting commission fell within the Explanation to section 10(23G) as commission for extending a guarantee or enhancing credit, and structuring fees were included within the expanded definition of interest in section 2(28A) as service fee or other charge connected with borrowed money. On deductions, the court held that sections 36(1)(viia)(c) and 36(1)(viii) operate independently, so deduction under one provision cannot be deferred until the other is exhausted; the amendment to section 36(1)(viii) affected only computation. The questions addressed were answered in favour of the assessee.
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