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...
Diversion of income by overriding title arose where a collaboration agreement, banking records, ledger accounts and supporting material established the collaborator's entitlement to a share of flat-sale proceeds. That share did not accrue as the assessee's income because the agreement imposed an overriding obligation; procedural non-compliance, stamp-paper objections, lack of witnesses or doubts about expertise did not establish a fictitious income-diversion device. The resulting addition was deleted. Land acquisition cost could not be disallowed on the basis that it was absent from the books, since the books recorded the land and the purchase deed substantiated acquisition. The unexplained-source inference and related disallowance were deleted.
Diversion of income by overriding title arose where a collaboration agreement, banking records, ledger accounts and supporting material established the collaborator's entitlement to a share of flat-sale proceeds. That share did not accrue as the assessee's income because the agreement imposed an overriding obligation; procedural non-compliance, stamp-paper objections, lack of witnesses or doubts about expertise did not establish a fictitious income-diversion device. The resulting addition was deleted. Land acquisition cost could not be disallowed on the basis that it was absent from the books, since the books recorded the land and the purchase deed substantiated acquisition. The unexplained-source inference and related disallowance were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
