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...
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.
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