Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
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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