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...
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Ad hoc disallowance of employee-benefit and business expenditure lacks basis where no expenditure is identified as non-genuine, excessive or non-business, and the books are not rejected; missing vouchers justify item-specific verification, not a blanket estimate. Cash deposits attributed to recorded multi-outlet sales cannot be reclassified as unexplained cash credits without evidence that they comprised Specified Bank Notes or that the underlying books, sales or stock records were defective; taxing recorded receipts again produces double taxation. Loan credits require verification of lender records, immediate source, and repayment or adjustment entries; confirmations, PAN details and banking entries require assessment alongside those records, while unsecured or interest-free terms alone do not justify an addition.
Ad hoc disallowance of employee-benefit and business expenditure lacks basis where no expenditure is identified as non-genuine, excessive or non-business, and the books are not rejected; missing vouchers justify item-specific verification, not a blanket estimate. Cash deposits attributed to recorded multi-outlet sales cannot be reclassified as unexplained cash credits without evidence that they comprised Specified Bank Notes or that the underlying books, sales or stock records were defective; taxing recorded receipts again produces double taxation. Loan credits require verification of lender records, immediate source, and repayment or adjustment entries; confirmations, PAN details and banking entries require assessment alongside those records, while unsecured or interest-free terms alone do not justify an addition.
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