Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Characterization of income - Income by way of winnings from lotteries on unsold lottery tickets - Winnings from lottery is read with the other kinds of winnings included within the ambit of section 2(24)(ix) of the Act, it becomes apparent that it is only attracted to those people who have such winnings by reason of their participation in draw of lottery as part of their hobby or enjoyment or pastime. If these winnings have arisen as part of business of distribution of lottery tickets, then such winnings cannot be regarded as ‘winnings from lotteries‘ u/s 2(24)(ix) of the Act but would be taxable as profits and gains of business of distribution of lottery tickets. - AT
Characterization of income - Income by way of winnings from lotteries on unsold lottery tickets - Winnings from lottery is read with the other kinds of winnings included within the ambit of section 2(24)(ix) of the Act, it becomes apparent that it is only attracted to those people who have such winnings by reason of their participation in draw of lottery as part of their hobby or enjoyment or pastime. If these winnings have arisen as part of business of distribution of lottery tickets, then such winnings cannot be regarded as ‘winnings from lotteries‘ u/s 2(24)(ix) of the Act but would be taxable as profits and gains of business of distribution of lottery tickets. - AT
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