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 50B prescribes a self-contained method for computing capital gains on a slump sale, including fair market value and net worth under Rule 11UAE. Where no defect in the valuation methodology or non-compliance with Rule 11UAE is identified, the Assessing Officer cannot substitute a different valuation; deletion of the resulting capital-gains addition was confirmed. A capital-gains addition made without a proper show-cause notice also breached CBDT Instruction No. 20/2015 and was independently unsustainable. The Revenue's appeal was dismissed.
Section 50B prescribes a self-contained method for computing capital gains on a slump sale, including fair market value and net worth under Rule 11UAE. Where no defect in the valuation methodology or non-compliance with Rule 11UAE is identified, the Assessing Officer cannot substitute a different valuation; deletion of the resulting capital-gains addition was confirmed. A capital-gains addition made without a proper show-cause notice also breached CBDT Instruction No. 20/2015 and was independently unsustainable. The Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
