Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
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Foreign exhibition-sale income already assessed under the Income-tax Act through a final Settlement Commission order is excluded from undisclosed foreign income under the Black Money Act, 2015. Section 4(2) excludes foreign-source income variations made in assessment or reassessment under business-income provisions, while Sections 4(2) and 4(3) prevent the same income from being taxed again. Settlement proceedings culminating in a final order are described as a statutory mode of assessment; accordingly, foreign sales considered and taxed as business profits in those proceedings cannot be reassessed under the 2015 Act, as that would produce impermissible double taxation.
Foreign exhibition-sale income already assessed under the Income-tax Act through a final Settlement Commission order is excluded from undisclosed foreign income under the Black Money Act, 2015. Section 4(2) excludes foreign-source income variations made in assessment or reassessment under business-income provisions, while Sections 4(2) and 4(3) prevent the same income from being taxed again. Settlement proceedings culminating in a final order are described as a statutory mode of assessment; accordingly, foreign sales considered and taxed as business profits in those proceedings cannot be reassessed under the 2015 Act, as that would produce impermissible double taxation.
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