SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.
Limitation for a fresh assessment ordered through a rectification order is computed from the rectification order where it forms part of the appellate order and directs a de novo assessment; assessments completed on that basis remain timely. For the alleged LOC-scam income addition, submission of periodic status reports on the related CBI prosecution was required. Because the required information was not fully supplied, the addition required fresh assessment after consideration of a detailed status report, existing material, and further evidence. Continued non-compliance permits the Assessing Officer to draw an adverse inference.
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