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...
Pre-scheme voluntary tax payments attributable to undisclosed income declared under the Income Declaration Scheme, 2016 may be credited against Scheme liability. Although section 187 requires full payment by the notified date, it does not prohibit adjustment of earlier self-assessment tax where the payment is linked to the declared income, recorded in the declaration, and supported by proof of payment. Relatable prepaid tax retains its character as tax and must be adjusted against tax, surcharge and penalty payable under the Scheme. Declarations were therefore to be treated as fully paid, with Form No. 4 to issue.
Pre-scheme voluntary tax payments attributable to undisclosed income declared under the Income Declaration Scheme, 2016 may be credited against Scheme liability. Although section 187 requires full payment by the notified date, it does not prohibit adjustment of earlier self-assessment tax where the payment is linked to the declared income, recorded in the declaration, and supported by proof of payment. Relatable prepaid tax retains its character as tax and must be adjusted against tax, surcharge and penalty payable under the Scheme. Declarations were therefore to be treated as fully paid, with Form No. 4 to issue.
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TaxTMI 
TaxTMI 
of 4913 
