SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
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Section 72(c) of the Black Money Act creates a conclusive, self-executing fiction: undeclared foreign assets acquired before the Act commenced are deemed acquired in the previous year when a Section 10 notice is issued. Assessment must follow in the immediately succeeding assessment year. Where no declaration was made, Section 72(b) does not apply. A first notice in FY 2018-19 therefore permits assessment only for AY 2019-20, rendering assessment for AY 2018-19 without jurisdiction and invalidating consequential proceedings.
Section 72(c) of the Black Money Act creates a conclusive, self-executing fiction: undeclared foreign assets acquired before the Act commenced are deemed acquired in the previous year when a Section 10 notice is issued. Assessment must follow in the immediately succeeding assessment year. Where no declaration was made, Section 72(b) does not apply. A first notice in FY 2018-19 therefore permits assessment only for AY 2019-20, rendering assessment for AY 2018-19 without jurisdiction and invalidating consequential proceedings.
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