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...
Taxation of surrendered income - taxability u/s 115BBE - the assessee had given complete explanation regarding the source of entries recorded in the diary, which were explained to be part of unrecorded sales and the AO also did not object to the said explanation. Therefore, addition cannot be made u/s 69A - and if the addition cannot be made u/s 69A, the provisions of section 115BBE will not be applicable. - AT
Taxation of surrendered income - taxability u/s 115BBE - the assessee had given complete explanation regarding the source of entries recorded in the diary, which were explained to be part of unrecorded sales and the AO also did not object to the said explanation. Therefore, addition cannot be made u/s 69A - and if the addition cannot be made u/s 69A, the provisions of section 115BBE will not be applicable. - AT
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