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...
Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.
Section 153C proceedings cannot be initiated where the deemed date of search falls after 1 April 2021. Under the proviso to section 153C(1), that date is when the searched person's Assessing Officer records satisfaction and forwards seized material to the assessee's Assessing Officer. Where forwarding occurred after that date, section 153C(3) rendered the provision inapplicable, resulting in quashing of the notice and consequential assessment; other grounds became academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
