Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Surrendered income arising from cash and stock discrepancies at business premises, and disclosed in the profit and loss account, is treated as business income where no independent undisclosed asset or non-business source is identified. The enhanced tax rate under section 115BBE, effective from 1 April 2017 without express retrospective operation, does not apply to FY 2016-17. Where competing reasonable interpretations of an ambiguous taxing provision are available and no jurisdictional High Court ruling governs, the interpretation favourable to the assessee applies. The surrendered income is consequently taxable at the normal business-income rate.
Surrendered income arising from cash and stock discrepancies at business premises, and disclosed in the profit and loss account, is treated as business income where no independent undisclosed asset or non-business source is identified. The enhanced tax rate under section 115BBE, effective from 1 April 2017 without express retrospective operation, does not apply to FY 2016-17. Where competing reasonable interpretations of an ambiguous taxing provision are available and no jurisdictional High Court ruling governs, the interpretation favourable to the assessee applies. The surrendered income is consequently taxable at the normal business-income rate.
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