Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.
Enhanced taxation of unexplained income under the amended Section 115BBE was treated as prospective, applying from Assessment Year 2018-19 rather than Assessment Year 2017-18. Where High Court decisions conflict and no binding jurisdictional High Court or Supreme Court ruling exists, the interpretation favourable to the assessee applies; tax for the earlier year is therefore computed under the unamended provision. Cash deposits used to repay a bank loan may be treated as unexplained money under Section 69A when their source lacks documentary support, but the entire deposit need not be added if reasonable cash-in-hand is available for ordinary requirements. The unexplained-money addition was consequently restricted.
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