S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-Comparable uncontrolled price-Royalty-Other method-Royalty payments made for unique intangibles-Directed to substitute working for other method.[R.10AB]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-Comparable uncontrolled price-Royalty-Other method-Royalty payments made for unique intangibles-Directed to substitute working for other method.[R.10AB]
S. 90 :Double taxation relief-Non-Resident-Salary —Long term international assignment-Salary earned in Singapore offered to tax in Singapore and taxes paid-Salary taxable in country where employment exercised-Income not taxable in India-DTAA-India-Singapore [S. 5(2), 15, art. 15, 25]
S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Not involved in any other activity other than running of port-Irrespective of various income declared by assessee in nature of duty credit entitlement, interest income, reversal of provision, small scarp sales etc., any income generated out of this port would be eligible for deduction.
S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Late payment surcharge and rebate on power of purchase-Receipts having nexus with profits-Eligible for deduction-Addition made to income of eligible unit-Eligible for deduction in respect of sums added. Central Board Of Direct Taxes Circular No. 37 Of 2016, Dated 2-11-2016.
S. 69A : Unexplained money-High net worth individuals-Sufficiently demonstrating plausibility for holding gold ornaments in excess of limit prescribed by Board’s Instruction-Credit to be given for gold, jewellery and ornaments held in custody of Assessee on behalf of sister-in-law-Addition is deleted. [S. 132]
S. 69A : Unexplained money-Search-loose papers-Commodity trade-Recharacterising nature of income offered by assessee-Surrendered income cannot be treated as unexplained money-Provision of section 115BBE cannot be applied.[S. 68, 69, 69A, 69B, 69C 69D, 115BBE]
S. 69A : Unexplained money-Search and seizure-Cash belonging to two concerns not functioning from same premises-Could not be considered in hands of assessee-Deletion of addition is proper
S. 69A : Unexplained money-Cash deposit-Demonetisation period-Not explained the source of fund-Addition is affirmed.
S. 69A : Unexplained money-Cash deposits from withdrawals-Addition is deleted. [S.92CA, 144C]
S. 68: Cash credits —Amount deposited on account of sale of agricultural produce-Department could not rebut arguments of Assessee —Addition is deleted-Real estate business-Assessee on protective basis is not justified