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...
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Cash and transfer entries from a subsequent financial year were included in the Assessment Year 2022-23 assessment, despite the relevant year being Financial Year 2021-22. The High Court treated the unresolved revisional challenge to those entries as material and held that its inadequate consideration vitiated both the assessment and revisional orders. Those orders were set aside, and the assessing authority must make a fresh determination within two months in accordance with law. The merits of the unexplained cash-deposit addition remain open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
