The Court held that invocation of the bank guarantee after expiry of the defect liability period was arbitrary. It ruled that absence of defects and delay invalidated the encashment action.
The Court held that the secured creditor’s rights were limited to project receivables and did not extend to management or contractual control. It ruled that the creditor could not challenge termination of the contract. The decision clarifies limits of secured creditor rights under IBC and SARFAESI.
The Court addressed whether additional remuneration taxed at the firm level can be taxed again in the hands of the partner. It directed CBDT to clarify the issue and stayed recovery proceedings. The ruling highlights concerns over potential double taxation.
Income Tax Department Ministry of Finance, Government of India DTAA & FTC Double Taxation Avoidance Agreement (DTAA) & Foreign Tax Credit (FTC) Double Taxation Avoidance Agreement (DTAA) & Foreign Tax Credit (FTC) Introduction The Double Taxation Avoidance Agreement (DTAA) is an agreement between India and other countries to avoid double taxation, ensure the exchange of […]
This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and streamlined compliance under prescribed conditions.
The issue concerns arrangements structured primarily to obtain tax benefits. It was held that such arrangements can be disregarded or recharacterised under GAAR to neutralise tax avoidance.
The case explains the statutory framework governing appeals and revisions under the Income-tax Act. It highlights the role of faceless schemes in ensuring electronic filing, allocation, and disposal of appeals.v
The framework outlines different assessment types to verify income and tax liability. It ensures accuracy through self, summary, scrutiny, and reassessment procedures.
The framework introduces electronic assessments, appeals, and penalties without physical interaction. It enhances transparency and efficiency through automated allocation and digital processes.
The framework outlines the hierarchy of tax authorities and the role of CBDT in administration. It clarifies that while CBDT can issue directions, it cannot influence assessment outcomes.
