Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Section 115BBE applies only after income is validly classified...
Survey surrender characterisation determines whether mixed excess stock and business-linked cash face normal taxation or special deemed-income taxation.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Section 115BBE applies only after income is validly classified under the specified deeming provisions; a survey surrender alone is insufficient. Excess stock inseparable from regular inventory and credibly linked to unrecorded business receipts may be assessed as business income under Section 28 at normal rates. Excess cash may receive the same treatment where its business source is satisfactorily explained; otherwise, the statutory conditions for deemed income must be met. Classification requires a holistic assessment of statements and contemporaneous evidence. The substituted enhanced rate applies prospectively from financial year 2017-18, while financial year 2016-17 is governed by the earlier rate.
Section 115BBE applies only after income is validly classified under the specified deeming provisions; a survey surrender alone is insufficient. Excess stock inseparable from regular inventory and credibly linked to unrecorded business receipts may be assessed as business income under Section 28 at normal rates. Excess cash may receive the same treatment where its business source is satisfactorily explained; otherwise, the statutory conditions for deemed income must be met. Classification requires a holistic assessment of statements and contemporaneous evidence. The substituted enhanced rate applies prospectively from financial year 2017-18, while financial year 2016-17 is governed by the earlier rate.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
