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...
Unexplained deposits - Amount found deposited in the joint account of assessee as well as his wife in the savings bank account - Even if it is presumed that the deposits made in the Axis Bank which has not been disclosed to the department was taken as correct still the entire amount cannot be taxed as done by the lower authorities. Therefore, taking into consideration of the fact that the assessee is into the contractual business which has not been disputed by the AO/Ld. CIT(A), for the ends of justice the presumptive tax @ 8% of the total amount is confirmed and the balance amount is directed to be deleted. - AT
Unexplained deposits - Amount found deposited in the joint account of assessee as well as his wife in the savings bank account - Even if it is presumed that the deposits made in the Axis Bank which has not been disclosed to the department was taken as correct still the entire amount cannot be taxed as done by the lower authorities. Therefore, taking into consideration of the fact that the assessee is into the contractual business which has not been disputed by the AO/Ld. CIT(A), for the ends of justice the presumptive tax @ 8% of the total amount is confirmed and the balance amount is directed to be deleted. - AT
Note: It is a system-generated summary and is for quick reference only.