Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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