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...
Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.
Pre-cut-off notice issued under section 87(b) to create a bank-account lien, which stated the outstanding service tax duty, constituted written quantification of duty payable under section 121(r) of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. Quantification remained sufficient although the notice did not quantify interest and was addressed to the bank rather than the taxpayer. The service tax dues therefore stood quantified, making the taxpayer eligible for Scheme benefits; rejection of the declaration for lack of quantification was unsustainable, and writ relief followed.
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