Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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Full and true disclosure under Section 245C(1) must extend to the entire settlement application, including the manner in which undisclosed income was derived and supporting particulars. A voluntary disclosure does not remove this statutory requirement; failure to substantiate a disputed income component can invalidate the settlement application as a whole, rather than permit piecemeal consideration. The notes further state that the Settlement Commission must examine the application as filed and cannot recharacterise income disclosed as business income under Section 69B or apply Section 115BBE. Any alternative assessment and consequential tax treatment must arise in regular assessment proceedings before the Assessing Officer.
Full and true disclosure under Section 245C(1) must extend to the entire settlement application, including the manner in which undisclosed income was derived and supporting particulars. A voluntary disclosure does not remove this statutory requirement; failure to substantiate a disputed income component can invalidate the settlement application as a whole, rather than permit piecemeal consideration. The notes further state that the Settlement Commission must examine the application as filed and cannot recharacterise income disclosed as business income under Section 69B or apply Section 115BBE. Any alternative assessment and consequential tax treatment must arise in regular assessment proceedings before the Assessing Officer.
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