Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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