Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s decision, noting the AO had treated the assessee as a non-resident and that the global income would only be taxable in India if it accrued or arose in India. - Further, the Tribunal reversed the CIT(A)'s decision on the disallowance of land filling expenses, accepting the assessee's argument regarding non-applicability of TDS deduction requirements due to not being under tax audit as per section 44AB in the preceding year.
Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s decision, noting the AO had treated the assessee as a non-resident and that the global income would only be taxable in India if it accrued or arose in India. - Further, the Tribunal reversed the CIT(A)'s decision on the disallowance of land filling expenses, accepting the assessee's argument regarding non-applicability of TDS deduction requirements due to not being under tax audit as per section 44AB in the preceding year.
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