Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Interest on undisclosed foreign income under the Black Money Act requires non-disclosure of the foreign source in the return; estimation or variation of income from an already disclosed foreign account does not satisfy that condition. Timely filing also prevents interest under the incorporated late-filing computation provisions. Advance-tax interest cannot be imposed without clear statutory language establishing the liability and machinery, and incorporated advance-tax provisions include exemptions for resident senior citizens without business income. Where rectification adds interest linked to the underlying foreign-income addition, the original and rectified orders operate as a composite order, permitting a limited challenge to the connected quantum addition; that issue requires merits consideration.
Interest on undisclosed foreign income under the Black Money Act requires non-disclosure of the foreign source in the return; estimation or variation of income from an already disclosed foreign account does not satisfy that condition. Timely filing also prevents interest under the incorporated late-filing computation provisions. Advance-tax interest cannot be imposed without clear statutory language establishing the liability and machinery, and incorporated advance-tax provisions include exemptions for resident senior citizens without business income. Where rectification adds interest linked to the underlying foreign-income addition, the original and rectified orders operate as a composite order, permitting a limited challenge to the connected quantum addition; that issue requires merits consideration.
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