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...
Approval of a resolution plan settling confirmed government dues causes the corporate debtor's pending excise appeal to abate. Excise duty remains payable by persons who clear processed fabrics, even where they are not manufacturers, because liability attaches on clearance; however, the transferee's specific penalty concerning stock was not sustained. Pre-clearance grading, cartage, brokerage and stock-interest expenses form part of assessable value where goods enter wholesale trade only on sale to independent buyers, sustaining the related duty and interest. Penalty for intent to evade duty requires findings of prescribed conduct and cannot rest solely on inadmissible valuation deductions. Penalties relating to confiscable goods likewise require their statutory basis; general penalties may instead apply to proven participation in duty evasion.
Approval of a resolution plan settling confirmed government dues causes the corporate debtor's pending excise appeal to abate. Excise duty remains payable by persons who clear processed fabrics, even where they are not manufacturers, because liability attaches on clearance; however, the transferee's specific penalty concerning stock was not sustained. Pre-clearance grading, cartage, brokerage and stock-interest expenses form part of assessable value where goods enter wholesale trade only on sale to independent buyers, sustaining the related duty and interest. Penalty for intent to evade duty requires findings of prescribed conduct and cannot rest solely on inadmissible valuation deductions. Penalties relating to confiscable goods likewise require their statutory basis; general penalties may instead apply to proven participation in duty evasion.
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