Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Undisclosed business receipts following rejection of books require profit estimation at a fair rate based on disclosed margins, past results and comparable data; the estimated rate was reduced to 12%. Impounded-document presumptions are rebuttable, and entries cannot be selectively used while corresponding outgoings are ignored; unsupported additions were deleted. Standard off-the-shelf software acquired for internal use without copyright transfer is a goods purchase, so no tax deduction at source applies. Stock statements given to banks, uncorroborated loose-sheet notings and estimated election-expense papers cannot alone establish unexplained investment or expenditure. Rejected books cannot support a separate cash-credit addition after business income is estimated; peak-credit and telescoping claims require reconciliation. The enhanced section 115BBE rate was inapplicable to FY 2016-17 income.
Undisclosed business receipts following rejection of books require profit estimation at a fair rate based on disclosed margins, past results and comparable data; the estimated rate was reduced to 12%. Impounded-document presumptions are rebuttable, and entries cannot be selectively used while corresponding outgoings are ignored; unsupported additions were deleted. Standard off-the-shelf software acquired for internal use without copyright transfer is a goods purchase, so no tax deduction at source applies. Stock statements given to banks, uncorroborated loose-sheet notings and estimated election-expense papers cannot alone establish unexplained investment or expenditure. Rejected books cannot support a separate cash-credit addition after business income is estimated; peak-credit and telescoping claims require reconciliation. The enhanced section 115BBE rate was inapplicable to FY 2016-17 income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
