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...
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 4894 
