Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Cash deposits made during the demonetization period in bank accounts accepted as receiving business turnover cannot be selectively treated as unexplained money solely because of their timing. The deeming fiction applies only where the Revenue establishes its statutory conditions, including material linking deposits to an independent undisclosed source. Where deposits show no abnormality or disproportionality against admitted business, gross receipts cannot be assessed entirely as unexplained money; only the profit embedded in turnover is assessable. The separate addition for such deposits was deleted, while the determined business income remained undisturbed.
Cash deposits made during the demonetization period in bank accounts accepted as receiving business turnover cannot be selectively treated as unexplained money solely because of their timing. The deeming fiction applies only where the Revenue establishes its statutory conditions, including material linking deposits to an independent undisclosed source. Where deposits show no abnormality or disproportionality against admitted business, gross receipts cannot be assessed entirely as unexplained money; only the profit embedded in turnover is assessable. The separate addition for such deposits was deleted, while the determined business income remained undisturbed.
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