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...
Unutilised capital gains claiming section 54 exemption must be deposited in the Capital Gains Account Scheme by the section 139(1) return-filing date where they have not been used for eligible residential investment. Exemption remains available only for gains utilised by that date; later payments do not qualify. This limitation applies even where two adjacent residential units are treated as one residential unit. The exemption was restricted to timely utilised gains, and interest under sections 234B and 234D was sustained as consequential and mandatory.
Unutilised capital gains claiming section 54 exemption must be deposited in the Capital Gains Account Scheme by the section 139(1) return-filing date where they have not been used for eligible residential investment. Exemption remains available only for gains utilised by that date; later payments do not qualify. This limitation applies even where two adjacent residential units are treated as one residential unit. The exemption was restricted to timely utilised gains, and interest under sections 234B and 234D was sustained as consequential and mandatory.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
