SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
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