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 on expenses attributable to the fresh issue component of an initial public offering is available where the net proceeds are used in furtherance of the company's business. Services used to raise capital for expansion, capital expenditure, working capital, repayment of borrowings and other business purposes have a substantial nexus with business operations and do not fall within blocked credits. In contrast, credit is unavailable for expenses attributable to an offer for sale by existing shareholders because those proceeds accrue to the shareholders rather than the company.
Input tax credit on expenses attributable to the fresh issue component of an initial public offering is available where the net proceeds are used in furtherance of the company's business. Services used to raise capital for expansion, capital expenditure, working capital, repayment of borrowings and other business purposes have a substantial nexus with business operations and do not fall within blocked credits. In contrast, credit is unavailable for expenses attributable to an offer for sale by existing shareholders because those proceeds accrue to the shareholders rather than the company.
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