Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
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...
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Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
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