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...
Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.
Reassessment notice describing an assessee both as the searched person and as a non-searched person was invalid because it failed to identify the basis on which reassessment was initiated, demonstrating non-application of mind. Approval for reassessment was also invalid where the escaped-income amount in the approval materially differed from the amount in the recorded reasons, showing that the approving authority had not properly considered the proposal. The assessment order was consequently quashed, while remaining grounds were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
