Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Section 153(5) applies where effect can be given without making a fresh assessment or reassessment. Where a Tribunal remand requires the Assessing Officer to undertake fresh consideration, the limitation period for fresh assessment under section 153(3) applies; the proviso to section 153(5) also covers matters requiring verification or an opportunity of hearing. Foreign currency may be treated as unexplained money where the taxpayer provides inconsistent explanations and fails to prove its source through satisfactory evidence, including acquisition from authorised dealers. FEMA confiscation for excess possession does not by itself establish the currency's source for income-tax purposes. The addition as deemed income and the associated tax treatment were sustained.
Section 153(5) applies where effect can be given without making a fresh assessment or reassessment. Where a Tribunal remand requires the Assessing Officer to undertake fresh consideration, the limitation period for fresh assessment under section 153(3) applies; the proviso to section 153(5) also covers matters requiring verification or an opportunity of hearing. Foreign currency may be treated as unexplained money where the taxpayer provides inconsistent explanations and fails to prove its source through satisfactory evidence, including acquisition from authorised dealers. FEMA confiscation for excess possession does not by itself establish the currency's source for income-tax purposes. The addition as deemed income and the associated tax treatment were sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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