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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Enhanced tax on unexplained income under section 115BBE, and the linked penalty under section 271AAC, are explained as prospective only where the amendment contains no express retrospective language. The text states that the law in force on the first day of the relevant year governs assessment, and a later fiscal amendment cannot alter completed tax consequences by implication. It further notes that section 271AAC is dependent on valid application of section 115BBE, and that doubling the principal tax rate is a substantive and onerous change. On that basis, the enhanced rate was treated as applicable from 01.04.2017, not to Financial Year 2016-17.
Enhanced tax on unexplained income under section 115BBE, and the linked penalty under section 271AAC, are explained as prospective only where the amendment contains no express retrospective language. The text states that the law in force on the first day of the relevant year governs assessment, and a later fiscal amendment cannot alter completed tax consequences by implication. It further notes that section 271AAC is dependent on valid application of section 115BBE, and that doubling the principal tax rate is a substantive and onerous change. On that basis, the enhanced rate was treated as applicable from 01.04.2017, not to Financial Year 2016-17.
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