Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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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