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...
Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.
Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
