Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
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Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.
Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.
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