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...
FEMA adjudication requires the prescribed two-stage process: the adjudicating authority must form and communicate its opinion to hold an inquiry before granting a personal hearing. Non-compliance invalidated the adjudication order and consequential penalties, requiring fresh adjudication. Alleged FCCB contraventions also require consideration of the earlier RBI circular on eligibility to raise external commercial borrowings, alongside all relevant circulars and material. The matters were remitted for fresh determination after both sides received an opportunity.
FEMA adjudication requires the prescribed two-stage process: the adjudicating authority must form and communicate its opinion to hold an inquiry before granting a personal hearing. Non-compliance invalidated the adjudication order and consequential penalties, requiring fresh adjudication. Alleged FCCB contraventions also require consideration of the earlier RBI circular on eligibility to raise external commercial borrowings, alongside all relevant circulars and material. The matters were remitted for fresh determination after both sides received an opportunity.
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