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...
GST exemption applies to effluent and waste-treatment services supplied by a section 12AA-registered entity where those activities constitute charitable preservation of the environment. The specific nil-rate exemption prevails over the taxable entry for sewage and waste collection, treatment and disposal services, particularly where charitable status has been previously determined. Extended demand proceedings require strict proof of fraud, wilful misstatement, or deliberate suppression of material facts with intent to evade tax; a failure to declare tax liability alone is insufficient. A subsequently discontinued exemption claim and later tax payment do not establish prior intent to evade. The show-cause notice was quashed because the exemption was available and the conditions for invoking the extended-demand provision were absent.
GST exemption applies to effluent and waste-treatment services supplied by a section 12AA-registered entity where those activities constitute charitable preservation of the environment. The specific nil-rate exemption prevails over the taxable entry for sewage and waste collection, treatment and disposal services, particularly where charitable status has been previously determined. Extended demand proceedings require strict proof of fraud, wilful misstatement, or deliberate suppression of material facts with intent to evade tax; a failure to declare tax liability alone is insufficient. A subsequently discontinued exemption claim and later tax payment do not establish prior intent to evade. The show-cause notice was quashed because the exemption was available and the conditions for invoking the extended-demand provision were absent.
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