Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.
Article 24(2) of the India-Netherlands DTAA does not entitle an Indian permanent establishment of a Netherlands bank to domestic-company tax rates where it remains a foreign company; the section 90 Explanation treats a higher foreign-company rate as non-discriminatory. Article 7's separate-enterprise fiction requires consistent treatment: interest remitted by an Indian PE to its overseas head office or branches is taxable in India, requires withholding, and is disallowed if withholding fails; interest received from them is taxable PE business income. ATMs qualify as computers for depreciation based on functional utility. Accounting Standard 19 does not govern tax characterisation; vehicle hiring payments remain deductible revenue expenditure absent an intention to acquire ownership.
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