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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Presumptive taxation does not permit enhancement of declared business profit merely by applying average profit margins from preceding years. Although the Assessing Officer may examine a claim under the presumptive taxation regime, any challenge must rest on adverse material. A taxpayer declaring income under that regime is not required to maintain books of account solely for that reason, and a stated decline in profit margin cannot be rejected without material disproving the explanation. The Tribunal's majority view found the adopted net-profit rate unjustified and allowed the taxpayer's appeal.
Presumptive taxation does not permit enhancement of declared business profit merely by applying average profit margins from preceding years. Although the Assessing Officer may examine a claim under the presumptive taxation regime, any challenge must rest on adverse material. A taxpayer declaring income under that regime is not required to maintain books of account solely for that reason, and a stated decline in profit margin cannot be rejected without material disproving the explanation. The Tribunal's majority view found the adopted net-profit rate unjustified and allowed the taxpayer's appeal.
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