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...
Cash-payment disallowance under section 40A(3) depends on whether payments exceeding the prescribed daily limit were made to a single person, not merely on a voucher exceeding that limit. A consolidated voucher may record separate payments to multiple persons, each within the limit, and therefore may not establish a contravention. Supporting material omitted by an erstwhile tax consultant was admitted as additional evidence because the first appellate order had been passed without it. The ex parte appellate order and cash-payment disallowance were set aside and remitted to the Assessing Officer for verification and fresh adjudication, with all contentions left open.
Cash-payment disallowance under section 40A(3) depends on whether payments exceeding the prescribed daily limit were made to a single person, not merely on a voucher exceeding that limit. A consolidated voucher may record separate payments to multiple persons, each within the limit, and therefore may not establish a contravention. Supporting material omitted by an erstwhile tax consultant was admitted as additional evidence because the first appellate order had been passed without it. The ex parte appellate order and cash-payment disallowance were set aside and remitted to the Assessing Officer for verification and fresh adjudication, with all contentions left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
