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...
Natural justice in transfer-pricing proceedings requires a personal hearing, reasoned findings, and meaningful consideration of written submissions. Although the transfer-pricing order recorded that written replies had been considered, it neither disclosed that a personal hearing was granted nor addressed the contentions raised. The cryptic and unreasoned order was set aside, with directions for a fresh reasoned determination after a personal hearing. The time for completing the assessment was extended.
Natural justice in transfer-pricing proceedings requires a personal hearing, reasoned findings, and meaningful consideration of written submissions. Although the transfer-pricing order recorded that written replies had been considered, it neither disclosed that a personal hearing was granted nor addressed the contentions raised. The cryptic and unreasoned order was set aside, with directions for a fresh reasoned determination after a personal hearing. The time for completing the assessment was extended.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
