Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The Kerala Agricultural Income Tax Act, 1991 does not allow an amalgamated company to treat the amalgamating company's losses as its own for set-off. Section 12 permits carry forward only by the person who actually sustained the loss, and Section 54 on succession to business deals with assessment and recovery of dues, not transfer of loss relief to the successor. The scheme of amalgamation could not create a tax benefit absent in the statute. In any event, the claimed losses for the relevant year were beyond the eight-year carry-forward limit under Section 12, so the set-off was barred. The appeals were dismissed.
The Kerala Agricultural Income Tax Act, 1991 does not allow an amalgamated company to treat the amalgamating company's losses as its own for set-off. Section 12 permits carry forward only by the person who actually sustained the loss, and Section 54 on succession to business deals with assessment and recovery of dues, not transfer of loss relief to the successor. The scheme of amalgamation could not create a tax benefit absent in the statute. In any event, the claimed losses for the relevant year were beyond the eight-year carry-forward limit under Section 12, so the set-off was barred. The appeals were dismissed.
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