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...
GST exemption under Notification No. 12/2017 may apply to recovery of amounts under written-off housing loan accounts. As a statutory notification has force of law, its applicability constitutes a pure question of law capable of being raised at the appellate stage. Entry 27 covers services by way of extending loans, while entitlement to exemption for a particular recovery depends on cogent proof that it arose from a written-off housing loan in the relevant financial year. Certified banker's books are admissible as prima facie evidence, but supporting loan write-off records are required. A cross-objection is unnecessary where the respondent has received complete relief and may operate as a reply. Factual applicability remains for determination after consideration of the records.
GST exemption under Notification No. 12/2017 may apply to recovery of amounts under written-off housing loan accounts. As a statutory notification has force of law, its applicability constitutes a pure question of law capable of being raised at the appellate stage. Entry 27 covers services by way of extending loans, while entitlement to exemption for a particular recovery depends on cogent proof that it arose from a written-off housing loan in the relevant financial year. Certified banker's books are admissible as prima facie evidence, but supporting loan write-off records are required. A cross-objection is unnecessary where the respondent has received complete relief and may operate as a reply. Factual applicability remains for determination after consideration of the records.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
