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...
Addition of opening capital as unexplained investment u/s 69 - income from undisclosed sources - The Tribunal held that for such an addition to be justified, the Assessing Officer must provide a concrete rationale for not accepting the disclosed sources of income, which was not done in this case. This decision reinforces the principle that tax authorities must adhere to strict standards of evidence and rationale when alleging undisclosed income.
Addition of opening capital as unexplained investment u/s 69 - income from undisclosed sources - The Tribunal held that for such an addition to be justified, the Assessing Officer must provide a concrete rationale for not accepting the disclosed sources of income, which was not done in this case. This decision reinforces the principle that tax authorities must adhere to strict standards of evidence and rationale when alleging undisclosed income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
