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...
Section 132B's reference to a "person concerned" extends to a third-party claimant whose ownership of cash seized from another person's premises has been established in benami proceedings. Ownership establishes standing to seek release but does not itself satisfy the statutory conditions for release. The first proviso requires an application within the prescribed period explaining the nature and source of acquisition to the Assessing Officer's satisfaction; a bare release request is inadequate. Release was not accepted where the application was late and omitted that explanation, while source-related assessment proceedings remained pending or contemplated. Questions on the provisos' effect, including expiry of 120 days, were referred to a Larger Bench.
Section 132B's reference to a "person concerned" extends to a third-party claimant whose ownership of cash seized from another person's premises has been established in benami proceedings. Ownership establishes standing to seek release but does not itself satisfy the statutory conditions for release. The first proviso requires an application within the prescribed period explaining the nature and source of acquisition to the Assessing Officer's satisfaction; a bare release request is inadequate. Release was not accepted where the application was late and omitted that explanation, while source-related assessment proceedings remained pending or contemplated. Questions on the provisos' effect, including expiry of 120 days, were referred to a Larger Bench.
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