Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
Concurrent anticipatory-bail jurisdiction permits applications before either forum, while secured evidence may negate custodial interrogation in GST e...
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Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction.
Export quota premium is not equivalent to export-incentive receipts eligible for deduction under section 80HHC. Administrative circulars bind departmental authorities but cannot bind courts, override statutory language, or displace judicial interpretation. Equating premium from the transfer of export quota with receipts covered by the specified export-incentive provisions would create an impermissible legal fiction, particularly because such premium lacks characteristics of those receipts, including foreign-exchange realisation. Tax deductions must be construed strictly by reference to income derived and the statutory classification of eligible receipts; export quota premium therefore falls outside the claimed deduction.
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