Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
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Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
Additional claim for refund of excess dividend distribution tax on dividends paid to a Singapore shareholder at the treaty rate was admitted and remitted to the Assessing Officer for consideration after the Supreme Court larger Bench resolves the underlying issue. Reference to a larger Bench does not, by itself, prevent the Tribunal from following binding jurisdictional High Court precedent, although the merits were left open. Market research and media-measurement expenditure incurred by a media agency was treated as revenue expenditure because client agreements, invoices and the business model established commercial expediency and business nexus; absent contrary material on genuineness, quantum or reasonableness, deletion of disallowance was affirmed.
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