Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.
Jewellery found in an assessee's locker was treated as explained where government-approved valuation reports established its age and ownership by the assessee and family members. CBDT Instruction No. 1916 serves as a guiding consideration for jewellery attributable to family members, assessed with reference to family status, customary gifts and inheritance, and the surrounding circumstances. On these facts, the explanation of source was accepted and the addition for unexplained jewellery was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
