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...
Non-generation of an e-invoice bearing IRN/QR Code before movement of goods is a procedural breach, but it does not by itself warrant detention penalty under Section 129. Where the tax invoice, e-way bill and lorry receipt identify the parties, goods, value and tax liability, and a later e-invoice matches the transaction, the lapse does not conclusively establish intent to evade tax absent fictitious documents, mismatched goods, value suppression or concealed supply. On these facts, the Section 129 penalty was unsustainable, the appellate order was set aside, and consequential relief was granted subject to statutory procedure.
Non-generation of an e-invoice bearing IRN/QR Code before movement of goods is a procedural breach, but it does not by itself warrant detention penalty under Section 129. Where the tax invoice, e-way bill and lorry receipt identify the parties, goods, value and tax liability, and a later e-invoice matches the transaction, the lapse does not conclusively establish intent to evade tax absent fictitious documents, mismatched goods, value suppression or concealed supply. On these facts, the Section 129 penalty was unsustainable, the appellate order was set aside, and consequential relief was granted subject to statutory procedure.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
