Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
Special insurance income computation preserves statutory deductions while limiting transfer-pricing, withholding and disallowance adjustments for gene...
The search-penalty framework under section 271AAB(1) requires a finding that surrendered income meets the statutory definition of undisclosed income; surrender during search alone is insufficient. The notice and penalty order must specify the applicable statutory default or clause, because an admission in a search statement does not automatically attract the provision. Where the assessment order is appealed, search-penalty proceedings must be completed within six months of receipt of the appellate order; an order issued after that period is barred by limitation.
The search-penalty framework under section 271AAB(1) requires a finding that surrendered income meets the statutory definition of undisclosed income; surrender during search alone is insufficient. The notice and penalty order must specify the applicable statutory default or clause, because an admission in a search statement does not automatically attract the provision. Where the assessment order is appealed, search-penalty proceedings must be completed within six months of receipt of the appellate order; an order issued after that period is barred by limitation.
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