Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Anonymous donations received by a trust registered under section 12A and claiming exemption under section 11 are specifically governed by section 115BBC. As section 115BBC does not require records establishing anonymous donors' identity, name or address, absence of those particulars cannot justify treating such donations as unexplained cash credits under section 68. The donations are taxable at the prescribed rate under section 115BBC rather than being added as unexplained cash credits.
Anonymous donations received by a trust registered under section 12A and claiming exemption under section 11 are specifically governed by section 115BBC. As section 115BBC does not require records establishing anonymous donors' identity, name or address, absence of those particulars cannot justify treating such donations as unexplained cash credits under section 68. The donations are taxable at the prescribed rate under section 115BBC rather than being added as unexplained cash credits.
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