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...
Section 56(2)(x)(b), introduced by the Finance Act 2018 and applicable from Assessment Year 2019-20, operates prospectively. It cannot tax the difference between purchase consideration and stamp value where an immovable-property purchase agreement was executed in 2013 and substantial consideration was paid through banking channels before the provision was inserted. On those facts, the stamp-value-difference addition was deleted and the appellate order sustaining it was set aside.
Section 56(2)(x)(b), introduced by the Finance Act 2018 and applicable from Assessment Year 2019-20, operates prospectively. It cannot tax the difference between purchase consideration and stamp value where an immovable-property purchase agreement was executed in 2013 and substantial consideration was paid through banking channels before the provision was inserted. On those facts, the stamp-value-difference addition was deleted and the appellate order sustaining it was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
