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...
Time-barred DRP objections leave no valid objections for consideration. The AO must complete the assessment under section 144C(4)(b) on the basis of the draft order within the prescribed period and cannot await the DRP's disposal of belated objections. Statutory limitation binds both the assessee and the Revenue. A final assessment issued after that period because of such delay is barred by limitation, void ab initio, and liable to be quashed; merits need not be considered.
Time-barred DRP objections leave no valid objections for consideration. The AO must complete the assessment under section 144C(4)(b) on the basis of the draft order within the prescribed period and cannot await the DRP's disposal of belated objections. Statutory limitation binds both the assessee and the Revenue. A final assessment issued after that period because of such delay is barred by limitation, void ab initio, and liable to be quashed; merits need not be considered.
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