Timely pronouncement of reserved judgments requires defined timelines, transparency measures, and remedial pathways to protect liberty and effective j...
Settlement-price depression requires proof of manipulation, not merely short exposure, late selling, or below-market orders, preserving disclosure pen...
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
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For a vegetable-market commission agent claiming status as a kachha arhtia, sale proceeds handled for principals do not constitute turnover for tax-audit purposes; gross commission alone is relevant under the CBDT Circular. Status must be verified because no conclusive material ruled out own-account purchases or sales. The penalty issue was restored for limited verification: proof of exclusive agency eliminates the audit obligation and penalty; otherwise, the penalty's sustainability must be determined in accordance with law.
For a vegetable-market commission agent claiming status as a kachha arhtia, sale proceeds handled for principals do not constitute turnover for tax-audit purposes; gross commission alone is relevant under the CBDT Circular. Status must be verified because no conclusive material ruled out own-account purchases or sales. The penalty issue was restored for limited verification: proof of exclusive agency eliminates the audit obligation and penalty; otherwise, the penalty's sustainability must be determined in accordance with law.
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