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...
Genuineness of dematerialised equity-share transactions supporting a long-term capital-gains claim depends on documentary evidence, banking-channel payments and identifiable transaction records. Where taxpayers produce such evidence, an allegation that share-sale proceeds constitute unexplained cash credit requires specific defects or rebuttal of the material. An alleged commission expenditure linked solely to the asserted bogus share-sale proceeds is consequential and cannot independently sustain disallowance where the underlying allegation fails.
Genuineness of dematerialised equity-share transactions supporting a long-term capital-gains claim depends on documentary evidence, banking-channel payments and identifiable transaction records. Where taxpayers produce such evidence, an allegation that share-sale proceeds constitute unexplained cash credit requires specific defects or rebuttal of the material. An alleged commission expenditure linked solely to the asserted bogus share-sale proceeds is consequential and cannot independently sustain disallowance where the underlying allegation fails.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4896 
