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...
The statutory bar on admission of an advance-ruling application applies where the same question concerning the applicant is already pending or has been decided in proceedings. A transporter's supply-characterisation question-whether making vehicles available to another goods transport agency is exempt or taxable-formed the basis of a pending input-tax-credit reversal proceeding and had been decided for an earlier tax period. Both grounds precluded examination of classification, exemption, or taxability on the merits, and the application was rejected as not maintainable.
The statutory bar on admission of an advance-ruling application applies where the same question concerning the applicant is already pending or has been decided in proceedings. A transporter's supply-characterisation question-whether making vehicles available to another goods transport agency is exempt or taxable-formed the basis of a pending input-tax-credit reversal proceeding and had been decided for an earlier tax period. Both grounds precluded examination of classification, exemption, or taxability on the merits, and the application was rejected as not maintainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
