Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
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...
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Interest on unutilised government grant deposits was not taxable where the grant terms and accounts showed the funds and accrued interest belonged to the Government and the assessee remained only a custodian; the addition was deleted. TDS credit was not denied merely because the related interest was not taxable in the assessee's hands, as Rule 37BA credits tax to the deductee shown by the deductor, subject only to verification against any double claim; the matter was restored for that limited purpose. For MAT, interest on unutilised grant deposits and belated provident fund payment could not be added back unless covered by Explanation 1 to section 115JB, so those adjustments were deleted, while the provision for obsolete material was remitted for factual verification as to whether it was a provision or ascertained liability. Interest under section 234A could not be levied by reference to a revised return, because the provision applies only to delay in the original return; the levy was deleted.
Interest on unutilised government grant deposits was not taxable where the grant terms and accounts showed the funds and accrued interest belonged to the Government and the assessee remained only a custodian; the addition was deleted. TDS credit was not denied merely because the related interest was not taxable in the assessee's hands, as Rule 37BA credits tax to the deductee shown by the deductor, subject only to verification against any double claim; the matter was restored for that limited purpose. For MAT, interest on unutilised grant deposits and belated provident fund payment could not be added back unless covered by Explanation 1 to section 115JB, so those adjustments were deleted, while the provision for obsolete material was remitted for factual verification as to whether it was a provision or ascertained liability. Interest under section 234A could not be levied by reference to a revised return, because the provision applies only to delay in the original return; the levy was deleted.
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