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...
Unaccounted bricks and coal found during survey are to be taxed by treating the goods as supplied and applying assessment provisions, rather than through confiscation proceedings and penalty for excess stock. Where the entire confiscation order, including penalty and fine in lieu of confiscation, has been quashed and that finding remains unchallenged, no separate basis survives to maintain or restore the fine. Revenue appeals limited to restoration of the fine were therefore dismissed.
Unaccounted bricks and coal found during survey are to be taxed by treating the goods as supplied and applying assessment provisions, rather than through confiscation proceedings and penalty for excess stock. Where the entire confiscation order, including penalty and fine in lieu of confiscation, has been quashed and that finding remains unchallenged, no separate basis survives to maintain or restore the fine. Revenue appeals limited to restoration of the fine were therefore dismissed.
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