Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
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 based on additions identical to those made in an original search assessment cannot proceed while tax appeals challenging that assessment remain pending, where the original appellate authority considered the additions on merits as well as technical grounds. The High Court found that parallel reassessment would directly affect the pending appeals. Precedent permitting reassessment after an assessment was annulled solely on a technical ground did not apply. The reopening notice and consequential reassessment orders were quashed; the merits of the additions remain to be decided in the pending tax appeals.
Reassessment based on additions identical to those made in an original search assessment cannot proceed while tax appeals challenging that assessment remain pending, where the original appellate authority considered the additions on merits as well as technical grounds. The High Court found that parallel reassessment would directly affect the pending appeals. Precedent permitting reassessment after an assessment was annulled solely on a technical ground did not apply. The reopening notice and consequential reassessment orders were quashed; the merits of the additions remain to be decided in the pending tax appeals.
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TaxTMI 
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