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...
Section 250(6) requires an appellate authority to determine the points in appeal on merits and record reasons for its decision. Non-compliance with hearing notices does not permit a cryptic ex parte affirmation of reassessment additions without addressing the issues, undertaking necessary enquiries, or obtaining assessment records. Although the assessee must comply with notices, any ex parte disposal must remain a reasoned decision on merits. The non-speaking appellate order was set aside and remanded for fresh adjudication after opportunity to both parties; continued non-compliance permits ex parte adjudication on merits.
Section 250(6) requires an appellate authority to determine the points in appeal on merits and record reasons for its decision. Non-compliance with hearing notices does not permit a cryptic ex parte affirmation of reassessment additions without addressing the issues, undertaking necessary enquiries, or obtaining assessment records. Although the assessee must comply with notices, any ex parte disposal must remain a reasoned decision on merits. The non-speaking appellate order was set aside and remanded for fresh adjudication after opportunity to both parties; continued non-compliance permits ex parte adjudication on merits.
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TaxTMI 
TaxTMI 
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