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...
Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.
Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.
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TaxTMI 
TaxTMI 
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