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...
Unexplained election expenditure based on a seized notebook requires proof that the document belongs to or is linked with the taxpayer and independent corroboration of its entries. A notebook recovered from separate commission-agent business premises, without the taxpayer's name, verification from named persons, or other correlation, does not by itself establish unexplained expenditure despite the statutory presumption for seized documents. Undated alleged campaign payments must be assessed in the year supported by campaign, polling, search, and entry-related facts; meeting-schedule dates do not establish the year of payment.
Unexplained election expenditure based on a seized notebook requires proof that the document belongs to or is linked with the taxpayer and independent corroboration of its entries. A notebook recovered from separate commission-agent business premises, without the taxpayer's name, verification from named persons, or other correlation, does not by itself establish unexplained expenditure despite the statutory presumption for seized documents. Undated alleged campaign payments must be assessed in the year supported by campaign, polling, search, and entry-related facts; meeting-schedule dates do not establish the year of payment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
