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...
Intra-group technical and IT services are priced using a 10% cost mark-up, after crediting recoveries, because Safe Harbour margins did not apply for the relevant year. Actuarially measured pension and other employee-benefit liabilities arising from past service are accrued liabilities, while privilege-leave encashment remains deductible only on actual payment. Exempt-income expenditure requires limited recomputation excluding interest, considering only income-yielding investments, and capped at exempt income. Banking securities may be valued under a consistently followed recognised method reflecting real income; interest on non-performing advances or investments is not taxed where recovery is uncertain under prudential norms. Bad-debt provisions, recovery taxation, and deductions for non-rural write-offs require statutory-limit, prior-deduction, and factual verification. Foreign branch income remains included in Indian total income, subject to double-tax relief.
Intra-group technical and IT services are priced using a 10% cost mark-up, after crediting recoveries, because Safe Harbour margins did not apply for the relevant year. Actuarially measured pension and other employee-benefit liabilities arising from past service are accrued liabilities, while privilege-leave encashment remains deductible only on actual payment. Exempt-income expenditure requires limited recomputation excluding interest, considering only income-yielding investments, and capped at exempt income. Banking securities may be valued under a consistently followed recognised method reflecting real income; interest on non-performing advances or investments is not taxed where recovery is uncertain under prudential norms. Bad-debt provisions, recovery taxation, and deductions for non-rural write-offs require statutory-limit, prior-deduction, and factual verification. Foreign branch income remains included in Indian total income, subject to double-tax relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
