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...
Section 129(3) detention and penalty provisions should not be applied solely because an e-way bill has expired where invoices and transport documents are accurate. An unrebutted vehicle breakdown, coupled with no independent enquiry, does not support an adverse inference that goods were moved to evade tax. In these circumstances, expiry alone does not establish intent to evade tax, and detention, consequential tax and penalty cannot be sustained; deposited amounts are refundable in accordance with law.
Section 129(3) detention and penalty provisions should not be applied solely because an e-way bill has expired where invoices and transport documents are accurate. An unrebutted vehicle breakdown, coupled with no independent enquiry, does not support an adverse inference that goods were moved to evade tax. In these circumstances, expiry alone does not establish intent to evade tax, and detention, consequential tax and penalty cannot be sustained; deposited amounts are refundable in accordance with law.
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