Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Section 115BBE applies only to income properly brought within the deeming provisions in sections 68 to 69D; it does not independently tax income merely because it was surrendered or undisclosed during a survey. Each deeming provision has distinct foundational conditions that must be identified and satisfied. Where the assessment neither invoked a relevant deeming provision nor established that the surrendered income fell within sections 68 to 69D, the special rate cannot apply. The surrendered income was therefore taxable at the assessee's normal applicable rate.
Section 115BBE applies only to income properly brought within the deeming provisions in sections 68 to 69D; it does not independently tax income merely because it was surrendered or undisclosed during a survey. Each deeming provision has distinct foundational conditions that must be identified and satisfied. Where the assessment neither invoked a relevant deeming provision nor established that the surrendered income fell within sections 68 to 69D, the special rate cannot apply. The surrendered income was therefore taxable at the assessee's normal applicable rate.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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