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 ...
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 4884 
