Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Income declared in the survey carried out u/s 133A - Disallowance of salary to partners claimed u/s.40(b) - We are confronted with a situation, in which both the source and destination are business inasmuch as the source of the income is business and the destination of such income is again in the nature of business assets, that is, stock, cash and receivables. - As a fortiori, such an income will be considered as `Business income’ covered under Chapter IV-D of the Act forming part of book-profit for the purposes of allowing remuneration to partners. - AT
Income declared in the survey carried out u/s 133A - Disallowance of salary to partners claimed u/s.40(b) - We are confronted with a situation, in which both the source and destination are business inasmuch as the source of the income is business and the destination of such income is again in the nature of business assets, that is, stock, cash and receivables. - As a fortiori, such an income will be considered as `Business income’ covered under Chapter IV-D of the Act forming part of book-profit for the purposes of allowing remuneration to partners. - AT
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