Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
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...
As decided in Total Oil India (P.) Ltd., where a domestic company declares, distributes or pays dividend to a non-resident shareholder(s), the Additional Income-tax (Tax on Distributed Profits) payable by the domestic company u/s 115-O shall be at the rate mentioned therein and not at the rate applicable to the non-resident shareholder(s) as per the relevant DTAA. The domestic company can claim DTAA benefit only if the Contracting States intend to extend treaty protection for dividend distribution tax. Regarding applicability of transfer pricing regulations to operations carried out through qualifying ships where income is taxed under TTS, following assessee's own case, provisions of Chapter-X cannot be invoked to alter expenditure having no bearing on income computed under Chapter XII-G. Thus, transfer pricing regulations do not apply to income taxed under TTS.
As decided in Total Oil India (P.) Ltd., where a domestic company declares, distributes or pays dividend to a non-resident shareholder(s), the Additional Income-tax (Tax on Distributed Profits) payable by the domestic company u/s 115-O shall be at the rate mentioned therein and not at the rate applicable to the non-resident shareholder(s) as per the relevant DTAA. The domestic company can claim DTAA benefit only if the Contracting States intend to extend treaty protection for dividend distribution tax. Regarding applicability of transfer pricing regulations to operations carried out through qualifying ships where income is taxed under TTS, following assessee's own case, provisions of Chapter-X cannot be invoked to alter expenditure having no bearing on income computed under Chapter XII-G. Thus, transfer pricing regulations do not apply to income taxed under TTS.
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