Centralised assessment transfers after searches coordinate connected investigations without finally determining the assessee's tax liability or assess...
Unsigned third-party records cannot establish on-money payments without corroboration and cross-examination, requiring deletion of the related additio...
Service-tax exemptions for railway and Government works restrict de novo reassessment, while unsupported limitation and consultation failures invalida...
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Rupee-denominated non-convertible debentures are treated as debt instruments for the concessional interest-tax treatment contemplated by section 194LD, because statutory definitions encompass interest on money borrowed, debt incurred, debentures and other securities. The bond-debenture distinction does not affect eligibility where the instruments are rupee denominated and the investor satisfies the prescribed foreign portfolio investor and other conditions. A separate claim under section 194LC requires express consideration: where an objection is left unaddressed in the final assessment, a denial attributable to that claim cannot be sustained.
Rupee-denominated non-convertible debentures are treated as debt instruments for the concessional interest-tax treatment contemplated by section 194LD, because statutory definitions encompass interest on money borrowed, debt incurred, debentures and other securities. The bond-debenture distinction does not affect eligibility where the instruments are rupee denominated and the investor satisfies the prescribed foreign portfolio investor and other conditions. A separate claim under section 194LC requires express consideration: where an objection is left unaddressed in the final assessment, a denial attributable to that claim cannot be sustained.
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