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...
Input tax credit for construction of immovable property used in a rental business remains subject to statutory blocked-credit restrictions. Although renting is a taxable supply of services, the general business-use entitlement does not override the bar on works contract services for construction or goods and services used to construct immovable property on the taxpayer's own account. Taxable rental income alone neither meets the exception for further supply of works contract services nor establishes that a building is qualifying plant. Eligibility may depend on a fact-specific functionality analysis or proof that expenditure relates to a foundation or structural support integral to identified plant and machinery. Claims must also satisfy timing, documentary, disclosure and utilisation requirements; inadequate statutory disclosure may trigger fraud or suppression-based demand, interest and penalty exposure.
Input tax credit for construction of immovable property used in a rental business remains subject to statutory blocked-credit restrictions. Although renting is a taxable supply of services, the general business-use entitlement does not override the bar on works contract services for construction or goods and services used to construct immovable property on the taxpayer's own account. Taxable rental income alone neither meets the exception for further supply of works contract services nor establishes that a building is qualifying plant. Eligibility may depend on a fact-specific functionality analysis or proof that expenditure relates to a foundation or structural support integral to identified plant and machinery. Claims must also satisfy timing, documentary, disclosure and utilisation requirements; inadequate statutory disclosure may trigger fraud or suppression-based demand, interest and penalty exposure.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
