Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
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