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...
Recorded cash sales deposited during demonetisation cannot be treated as unexplained where books, sale bills, stock records and cash balances are accepted, since this would tax the same receipts twice. Rental income reflected in Form 26AS requires reconciliation and verification, with corresponding relief or tax credit where warranted. Business expenditure remains disallowable where the claim that tax withholding was unnecessary is unsupported. A challenge to penalty initiation before a penalty order is premature. Alleged unexplained receipts in a running account must account for debit entries and repayments rather than aggregate gross receipts. Reversal of overdraft interest is not taxable as cessation of liability when only net interest was debited and the reversed amount was not separately claimed.
Recorded cash sales deposited during demonetisation cannot be treated as unexplained where books, sale bills, stock records and cash balances are accepted, since this would tax the same receipts twice. Rental income reflected in Form 26AS requires reconciliation and verification, with corresponding relief or tax credit where warranted. Business expenditure remains disallowable where the claim that tax withholding was unnecessary is unsupported. A challenge to penalty initiation before a penalty order is premature. Alleged unexplained receipts in a running account must account for debit entries and repayments rather than aggregate gross receipts. Reversal of overdraft interest is not taxable as cessation of liability when only net interest was debited and the reversed amount was not separately claimed.
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