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...
Expansion of a show cause notice at the appellate stage cannot support rejection of accumulated input tax credit refunds without allowing the taxpayer to answer the added grounds. The High Court treated the notice as the foundation of proceedings and found that reliance on grounds introduced only in appeal deprived petitioners of an effective opportunity to reply. Without examining the merits of those grounds or the refund claim, the High Court set aside the adjudication and appellate orders and remitted the matter for fresh adjudication, requiring a comprehensive reply opportunity and personal hearing.
Expansion of a show cause notice at the appellate stage cannot support rejection of accumulated input tax credit refunds without allowing the taxpayer to answer the added grounds. The High Court treated the notice as the foundation of proceedings and found that reliance on grounds introduced only in appeal deprived petitioners of an effective opportunity to reply. Without examining the merits of those grounds or the refund claim, the High Court set aside the adjudication and appellate orders and remitted the matter for fresh adjudication, requiring a comprehensive reply opportunity and personal hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
