Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.
Professional income cannot be assessed by treating an entire doctor's gross receipts as net income solely because no return was filed. For a reasonable assessment, the taxpayer's offer of 50% of receipts as income, tax payment on that basis, and Revenue acceptance of the same approach in subsequent years for the identical profession were relevant, although they did not establish formal eligibility for presumptive taxation under section 44ADA for the relevant year. The Tribunal did not decide whether section 44ADA could be claimed without filing a return. Professional income was restricted to 50% of gross receipts; unpressed grounds were dismissed.
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