Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
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...
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Common expenditure proportionately allocated to taxable non-member receipts of a mutual concern is deductible where the expenses are genuine, relate to earning those receipts, and the allocation method has been consistently followed; an estimated restriction without disclosed basis or cogent material cannot stand. The disallowance was deleted. Rent from terrace space leased to a cellular operator for a tower was treated as income from house property, attracting statutory deductions rather than income from other sources. The appeal succeeded on those issues. The challenge to the scrutiny notice for alleged non-compliance with CBDT instructions was dismissed because a cited Special Bench ruling covered the issue against the assessee.
Common expenditure proportionately allocated to taxable non-member receipts of a mutual concern is deductible where the expenses are genuine, relate to earning those receipts, and the allocation method has been consistently followed; an estimated restriction without disclosed basis or cogent material cannot stand. The disallowance was deleted. Rent from terrace space leased to a cellular operator for a tower was treated as income from house property, attracting statutory deductions rather than income from other sources. The appeal succeeded on those issues. The challenge to the scrutiny notice for alleged non-compliance with CBDT instructions was dismissed because a cited Special Bench ruling covered the issue against the assessee.
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