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...
GST assessment was unsustainable where actual turnover had not been ascertained, an adjournment request was declined, and the taxpayer could not electronically file rectification because departmental creation of a temporary identification prevented portal access. Although personal-hearing notices were issued, the assessment followed soon after the final reminder, and no other works during the relevant period were asserted. The High Court directed the assessing authority to consider a fresh manual rectification application after hearing the taxpayer and barred coercive recovery until that decision.
GST assessment was unsustainable where actual turnover had not been ascertained, an adjournment request was declined, and the taxpayer could not electronically file rectification because departmental creation of a temporary identification prevented portal access. Although personal-hearing notices were issued, the assessment followed soon after the final reminder, and no other works during the relevant period were asserted. The High Court directed the assessing authority to consider a fresh manual rectification application after hearing the taxpayer and barred coercive recovery until that decision.
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