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...
Assignment of user rights in intangible assets, without a lump-sum price, fixed term, fixed periodic payment, or reversion provision, was characterised as a licence rather than an ownership transfer; variable profit-linked payments were licence fees, and later consideration was capital sale proceeds. Sale proceeds of self-generated trade marks and brands were not taxable as long-term capital gains where the acquisition cost was unascertainable and no retrospective nil-cost deeming rule applied. An arbitral award remained binding between its parties absent an evidential basis to impugn it. Deletion of the underlying addition eliminated the basis for concealment penalty.
Assignment of user rights in intangible assets, without a lump-sum price, fixed term, fixed periodic payment, or reversion provision, was characterised as a licence rather than an ownership transfer; variable profit-linked payments were licence fees, and later consideration was capital sale proceeds. Sale proceeds of self-generated trade marks and brands were not taxable as long-term capital gains where the acquisition cost was unascertainable and no retrospective nil-cost deeming rule applied. An arbitral award remained binding between its parties absent an evidential basis to impugn it. Deletion of the underlying addition eliminated the basis for concealment penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
