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...
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
Reassessment litigation concerns the authority to sanction notices, the jurisdiction of a Jurisdictional Assessing Officer to issue them, and whether the prescribed faceless mechanism requires issuance by a competent Faceless Assessment Officer. The 2021 amendments to sections 147 to 151, including new section 147A, may affect pending challenges. Following remand of related matters, the petition was closed with liberty to bring a fresh challenge on the same cause, challenge section 147A, and seek consequential relief. Existing protection continues for 90 days and ceases if no fresh approach is made within that period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
