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...
Capital grants, subsidies and consumer contributions reduce the actual cost or written-down value of relevant assets for depreciation. Where not directly attributable to a particular asset, they require allocation among the affected assets at their respective depreciation rates. Book-profit adjustments for such grants, including subsidy grants received in advance, require an identified clause in the Explanation to section 115JB(2); treatment under normal tax provisions alone is insufficient. Borrowing-cost capitalisation depends on direct attribution to qualifying capital projects and cannot rest on an unsupported assumed historical rate or unsubstantiated accounting-method change. Assistance for beneficiary-owned solar systems is revenue in nature, while business-linked staff-loan interest and miscellaneous receipts are business income; residual rental and staff recoveries may be income from other sources.
Capital grants, subsidies and consumer contributions reduce the actual cost or written-down value of relevant assets for depreciation. Where not directly attributable to a particular asset, they require allocation among the affected assets at their respective depreciation rates. Book-profit adjustments for such grants, including subsidy grants received in advance, require an identified clause in the Explanation to section 115JB(2); treatment under normal tax provisions alone is insufficient. Borrowing-cost capitalisation depends on direct attribution to qualifying capital projects and cannot rest on an unsupported assumed historical rate or unsubstantiated accounting-method change. Assistance for beneficiary-owned solar systems is revenue in nature, while business-linked staff-loan interest and miscellaneous receipts are business income; residual rental and staff recoveries may be income from other sources.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
