Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The Black Money Act distinguishes undisclosed foreign income...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act additions.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
The Black Money Act distinguishes undisclosed foreign income from an undisclosed foreign asset, and its deeming fiction for pre-commencement assets is confined to assets that remain unexplained. The notes state that foreign-bank credits supported by affidavits, plausible source explanations and corroborative material, including a family gift and an investment refund, cannot be treated as undisclosed merely because documentation is incomplete. Unrebutted affidavits cannot be rejected on suspicion where the revenue neither investigates the explanation nor cross-examines the deponents. On the stated facts, the deposits did not satisfy the definition of an undisclosed foreign asset, and the related additions were deleted.
The Black Money Act distinguishes undisclosed foreign income from an undisclosed foreign asset, and its deeming fiction for pre-commencement assets is confined to assets that remain unexplained. The notes state that foreign-bank credits supported by affidavits, plausible source explanations and corroborative material, including a family gift and an investment refund, cannot be treated as undisclosed merely because documentation is incomplete. Unrebutted affidavits cannot be rejected on suspicion where the revenue neither investigates the explanation nor cross-examines the deponents. On the stated facts, the deposits did not satisfy the definition of an undisclosed foreign asset, and the related additions were deleted.
Note: It is a system-generated summary and is for quick reference only.