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...
Profit on payments for subcontracted civil work cannot be separately estimated where the underlying contract receipts and profit have already been recorded, as this would duplicate disclosed profit; the related addition was deleted. A donation deduction remains disallowable where banking entries are unsupported by receipts. For delayed provident fund remittances, compensatory interest is deductible, whereas statutory damages for breach of payment obligations are penal and disallowable. The payment requires bifurcation between interest and damages, with the allowable interest component to be verified and permitted.
Profit on payments for subcontracted civil work cannot be separately estimated where the underlying contract receipts and profit have already been recorded, as this would duplicate disclosed profit; the related addition was deleted. A donation deduction remains disallowable where banking entries are unsupported by receipts. For delayed provident fund remittances, compensatory interest is deductible, whereas statutory damages for breach of payment obligations are penal and disallowable. The payment requires bifurcation between interest and damages, with the allowable interest component to be verified and permitted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
