The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s attempt to recharacterise the business and apply royalty-based valuation.
The article highlights that failure to serve proper notice under Rule 8 can invalidate proceedings. Adequate notice is a mandatory condition for fair hearing.
The law defines business broadly to include trade, commerce, and even single transactions. The key takeaway is that intent and nature of activity determine tax treatment.
Section 145(3) allows rejection of books if accounts are unreliable or standards are not followed. The key takeaway is that specific defects must be identified before invoking this power.
This article explains how AI tools may provide outdated tax advice under the new law. The key takeaway is that relying on unverified AI responses can lead to penalties.
The tribunal held that a gift deed alone cannot establish legitimacy under Section 68. It directed fresh scrutiny of the donor’s financial capacity.
Courts held that prior exemption claims under Sections 11 and 12 cannot justify denial of 80G approval. The key takeaway is that both benefits legally coexist.
The Supreme Court clarified that tax planning is valid only when backed by real commercial substance. It held that artificial structures without economic activity cannot claim treaty benefits.
The Court held that search action under tax law requires concrete material and cannot be based on assumptions. Lack of valid “reason to believe” made the search illegal.
The new tax law formally embeds faceless assessments into the statute, replacing the earlier scheme-based system and making electronic tax scrutiny the default process.
