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...
Refunds of pre-deposit arising from appellate relief must be determined under the appellate order; penalties already set aside cannot be recovered by appropriating the refund, and setting aside the Event Management Services demand makes the corresponding deposit refundable. For appeals pending when the statutory amendment took effect, the unamended Section 35FF regime applies. Interest on delayed pre-deposit refund accrues only if payment is not made within three months of the jurisdictional authority receiving the appellate order. The refund amount, due date and consequential interest require fresh computation.
Refunds of pre-deposit arising from appellate relief must be determined under the appellate order; penalties already set aside cannot be recovered by appropriating the refund, and setting aside the Event Management Services demand makes the corresponding deposit refundable. For appeals pending when the statutory amendment took effect, the unamended Section 35FF regime applies. Interest on delayed pre-deposit refund accrues only if payment is not made within three months of the jurisdictional authority receiving the appellate order. The refund amount, due date and consequential interest require fresh computation.
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