Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Categorization of income - Undisclosed income surrendered during survey - Charging of tax rate u/s. 115BBE - CIT(A) granted relief to the assessee by charging income at normal rate of tax - We cannot subscribe to the view expressed by the CIT(A), since the AO has accepted the income offered by the assessee comes under the head ‘Income from Other Sources’ and offered higher rate of tax on the said income, therefore, there was no occasion for the AO to go into the integrities of the books of accounts to make them liable to be rejected. - AT
Categorization of income - Undisclosed income surrendered during survey - Charging of tax rate u/s. 115BBE - CIT(A) granted relief to the assessee by charging income at normal rate of tax - We cannot subscribe to the view expressed by the CIT(A), since the AO has accepted the income offered by the assessee comes under the head ‘Income from Other Sources’ and offered higher rate of tax on the said income, therefore, there was no occasion for the AO to go into the integrities of the books of accounts to make them liable to be rejected. - AT
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