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...
Show-cause notice and a meaningful opportunity to respond are required before an assessment can make an addition as unexplained money. Where proposed variations notified to the taxpayer differed from the unexplained-money addition ultimately made, and no notice addressed that proposition, the taxpayer was denied an opportunity of hearing in breach of natural justice. The assessment order and consequential penalty notices were quashed, while preserving the revenue's right to commence fresh proceedings in accordance with law.
Show-cause notice and a meaningful opportunity to respond are required before an assessment can make an addition as unexplained money. Where proposed variations notified to the taxpayer differed from the unexplained-money addition ultimately made, and no notice addressed that proposition, the taxpayer was denied an opportunity of hearing in breach of natural justice. The assessment order and consequential penalty notices were quashed, while preserving the revenue's right to commence fresh proceedings in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
