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 limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Reassessment limitation excludes the period allowed for a response to a notice under section 148A(b) when calculating the three-year period under section 149(1). Once that exclusion applies, approval by the PCIT satisfies the specified-authority requirement under section 151(i), preserving the notice's validity. A political-party donation deduction under section 80GGC requires a genuine contribution; payment through banking channels and a receipt alone do not prove genuineness. Investigation material, statements, bank-trail analysis and evidence of layered funds may, under the test of human probabilities, establish an accommodation entry. Failure to rebut such material renders the deduction ineligible.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
