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...
Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.
Reverse burden of proof for notified gold is discharged when the carrier produces a delivery challan supporting lawful possession. The evidential burden then shifts to Revenue to prove foreign origin and smuggling. A town seizure, gold purity below 99.9%, and procurement records corroborated by GSTR-2A did not establish reasonable belief that the gold was smuggled. On those facts, confiscation was set aside and release of the gold was directed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
