Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
Rejection of books of account may be sustained where primary books, bills and vouchers are repeatedly not produced; an audit report does not replace records required for verification. Best-judgment disallowance of unverifiable expenditure must nevertheless rest on relevant material and bear a reasonable nexus to it, rather than amounting to a pure guess. Rejection of accounts alone does not justify an addition, and acceptance of recorded receipts or absence of objection to a proposed rate cannot supply evidentiary reasons. Adjacent-year audited financial statements, books and vouchers may be verified for fresh quantification after hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
