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...
Service of notice and opportunity of hearing were treated as adequate where the director knew of the investigation, sought time to respond, then neither replied nor updated the address despite repeated service attempts. No breach of natural justice arose from non-cooperation. Non-realisation of export proceeds triggered a statutory presumption that reasonable recovery steps had not been taken. As the director was in charge during the contravention and did not establish realisation or efforts to obtain information from the Official Liquidator, company liquidation did not remove liability. The penalty was sustained but confined to the amount already deposited, considering the elapsed period and liquidation.
Service of notice and opportunity of hearing were treated as adequate where the director knew of the investigation, sought time to respond, then neither replied nor updated the address despite repeated service attempts. No breach of natural justice arose from non-cooperation. Non-realisation of export proceeds triggered a statutory presumption that reasonable recovery steps had not been taken. As the director was in charge during the contravention and did not establish realisation or efforts to obtain information from the Official Liquidator, company liquidation did not remove liability. The penalty was sustained but confined to the amount already deposited, considering the elapsed period and liquidation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
