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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Revision u/s 263 - Correct source of income - special rate of tax u/s. 115BBE - As per CIT income of the assessee should have been assessed as unexplained cash credit, rather than business income - In assessee’s case the amount is not recorded in the books of accounts and directly offered to tax in the statement of computation (page 12 of paper book) as additional income under the head profits and gains of business or profession. - Provisions of section 68 not applicable - Revision order is not valid - AT
Revision u/s 263 - Correct source of income - special rate of tax u/s. 115BBE - As per CIT income of the assessee should have been assessed as unexplained cash credit, rather than business income - In assessee’s case the amount is not recorded in the books of accounts and directly offered to tax in the statement of computation (page 12 of paper book) as additional income under the head profits and gains of business or profession. - Provisions of section 68 not applicable - Revision order is not valid - AT
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