Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
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Additions (Benefit) u/s 28(iv) - Expenditure incurred by the HO for salary paid to the expatriate employees for rendering services to PE - The tribunal upheld the allowance of salary expenses paid to expatriate employees, rejecting the revenue's argument under Section 28(iv) of the Income Tax Act that unrecorded expenses should lead to deemed income. The tribunal agreed that since these expenses had already been subjected to tax as salary income in the employees' returns, they did not constitute a benefit under Section 28(iv).
Additions (Benefit) u/s 28(iv) - Expenditure incurred by the HO for salary paid to the expatriate employees for rendering services to PE - The tribunal upheld the allowance of salary expenses paid to expatriate employees, rejecting the revenue's argument under Section 28(iv) of the Income Tax Act that unrecorded expenses should lead to deemed income. The tribunal agreed that since these expenses had already been subjected to tax as salary income in the employees' returns, they did not constitute a benefit under Section 28(iv).
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