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...
Foreign life-insurance policy maturity proceeds were not treated as undisclosed foreign income or an undisclosed foreign asset where the investment source was satisfactorily explained. Premiums had been paid from income not chargeable to tax during non-resident status and later from salary already taxed in India; CBDT clarifications on explained foreign assets were stated to apply. The discussion also states that the life-insurance exemption does not confine its benefit to policies issued by Indian insurers. A definition of "insurer" in another provision could not be imported where the exemption provision did not adopt it or distinguish foreign insurers. Accordingly, the maturity proceeds were described as exempt and outside assessment under the Black Money Act.
Foreign life-insurance policy maturity proceeds were not treated as undisclosed foreign income or an undisclosed foreign asset where the investment source was satisfactorily explained. Premiums had been paid from income not chargeable to tax during non-resident status and later from salary already taxed in India; CBDT clarifications on explained foreign assets were stated to apply. The discussion also states that the life-insurance exemption does not confine its benefit to policies issued by Indian insurers. A definition of "insurer" in another provision could not be imported where the exemption provision did not adopt it or distinguish foreign insurers. Accordingly, the maturity proceeds were described as exempt and outside assessment under the Black Money Act.
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