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...
Writ jurisdiction against GST determinations involving fraud, wilful misrepresentation or suppression is generally unavailable where objections require resolution of disputed facts. Challenges concerning signatures, the form and content of show-cause notices, consideration of replies, and the hearing officer's authority require factual examination not ordinarily undertaken in writ proceedings. Form DRC-01 summaries identifying the demand and relevant taxable periods, coupled with an order that is not prima facie non-speaking and is passed by a proper officer, support recourse to the statutory appellate mechanism. A taxpayer cannot bypass the prescribed multi-tier appeal merely to avoid mandatory pre-deposit requirements.
Writ jurisdiction against GST determinations involving fraud, wilful misrepresentation or suppression is generally unavailable where objections require resolution of disputed facts. Challenges concerning signatures, the form and content of show-cause notices, consideration of replies, and the hearing officer's authority require factual examination not ordinarily undertaken in writ proceedings. Form DRC-01 summaries identifying the demand and relevant taxable periods, coupled with an order that is not prima facie non-speaking and is passed by a proper officer, support recourse to the statutory appellate mechanism. A taxpayer cannot bypass the prescribed multi-tier appeal merely to avoid mandatory pre-deposit requirements.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
