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...
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
Amended section 145A requires purchases and sales of goods or services to be valued inclusive of applicable taxes, duties, cess and fees; GST and service tax collected but unpaid by the return-filing date consequently attracted disallowance under section 43B. Interest for delayed payment of TDS was treated as penal and non-deductible business expenditure. Differences in commission claims versus tax-deducted commission payments, consolidated cash visa-fee entries, and gross receipts versus Form 26AS required supporting reconciliations or verification and were restored for examination. The indirect-tax and delayed-TDS-interest disallowances remained sustained, while the verification issues were remanded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
