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...
Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
