Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
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...
Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.
Extended-period reassessment requires recorded reasons to link escaped income to a prescribed asset, transaction-related expenditure, event or occasion, or book entry; unidentified unaccounted receipts or expenses alone do not satisfy that jurisdictional condition, invalidating the challenged reassessments. For the assessment year preceding the search year, a section 143(3) assessment cannot be completed without notice under sections 147/148. Digital material alleging unaccounted sales must demonstrate relevance, authenticity, integrity and probative value, with identifiable completed sales or receipts and independent corroboration. Uncontextualised WhatsApp chats, unrebutted retracted statements, unreconciled seized records, or backward projection of later-year material cannot establish year-specific taxable income or sustain profit estimation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
