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 jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.
Reassessment jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
