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...
Conditional release of a lien over provisionally attached fixed deposits can be granted where the outstanding revenue demand is adequately secured. A 20% deposit ordinarily supports a stay during appeal under the applicable CBDT circular; a 25% deposit, through a post-dated cheque, together with an undertaking not to transfer assets or create third-party rights, secured release of the lien. The Assessing Officer was required to lift the lien or recall the attachment and notify the bank once those conditions were met.
Conditional release of a lien over provisionally attached fixed deposits can be granted where the outstanding revenue demand is adequately secured. A 20% deposit ordinarily supports a stay during appeal under the applicable CBDT circular; a 25% deposit, through a post-dated cheque, together with an undertaking not to transfer assets or create third-party rights, secured release of the lien. The Assessing Officer was required to lift the lien or recall the attachment and notify the bank once those conditions were met.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
