Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
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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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