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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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