Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
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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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