SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.
Penalty notices for concealment or furnishing inaccurate particulars must specify the exact charge and remove the inapplicable alternative; retaining both charges invalidates initiation. Similarly, search-penalty notices for undisclosed income must identify the applicable statutory clause because alternate clauses impose distinct conditions and consequences; non-specification makes the proceedings defective. Salary expenditure disallowed as allegedly non-genuine services was treated as requiring fact-based inquiry, but the related additions were restricted to 10% with consequential relief. Penalties based on defective notices were untenable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
