Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Foreign-contribution disclosures under the FCRA and the income-tax return serve distinct reporting purposes and must be reconciled on substance rather than form. Foreign contributions and interest earned from them may be separately disclosed in audited accounts and the return even where the FCRA declaration includes both amounts. For processing under section 143(1), documents accompanying the return form part of the return; before making a mismatch adjustment, the CPC must provide an opportunity and consider the taxpayer's explanation in rectification proceedings. The adjustment treating the reporting difference as undisclosed income was deleted.
Foreign-contribution disclosures under the FCRA and the income-tax return serve distinct reporting purposes and must be reconciled on substance rather than form. Foreign contributions and interest earned from them may be separately disclosed in audited accounts and the return even where the FCRA declaration includes both amounts. For processing under section 143(1), documents accompanying the return form part of the return; before making a mismatch adjustment, the CPC must provide an opportunity and consider the taxpayer's explanation in rectification proceedings. The adjustment treating the reporting difference as undisclosed income was deleted.
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