Wednesday, January 13, 2016

Income initially disclosed before SetCom couldn't be said to be concealed if additions were made due to TP provisions

Where correct determination of income was dependent upon application of appropriate transfer pricing rule and, consequently, assessee made a revision in income initially disclosed before SetCom after considerable debate during the course of hearing, it could not be said that full and true disclosure of undisclosed income was not made in original application filed before SetCom.