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 appellate pre-deposit is cumulative, calculated against the tax still disputed in the Tribunal appeal, rather than requiring a separate fresh payment after the first appeal. A deposit already held against the same demand may be apportioned between both appellate stages, including amounts paid through FORM GST DRC-03, because pre-deposit forms part of disputed tax rather than an independent levy. Requiring refund and redeposit of the same sum would be anomalous. Deposits connected with separate proceedings cannot be double counted. Where the existing deposit meets the aggregate requirement, it may be appropriated and electronically mapped to the disputed demand, with no further deposit required.
GST appellate pre-deposit is cumulative, calculated against the tax still disputed in the Tribunal appeal, rather than requiring a separate fresh payment after the first appeal. A deposit already held against the same demand may be apportioned between both appellate stages, including amounts paid through FORM GST DRC-03, because pre-deposit forms part of disputed tax rather than an independent levy. Requiring refund and redeposit of the same sum would be anomalous. Deposits connected with separate proceedings cannot be double counted. Where the existing deposit meets the aggregate requirement, it may be appropriated and electronically mapped to the disputed demand, with no further deposit required.
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