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 u/s 271(1)(c) - defective show cause notice - the impugned SCN qualifies as a notice u/s 292B - it cannot be held to be invalid merely by mistake or defect of issuing it in a template and not scoring of the relevant ground and leaving out the applicable ground - Department allowed to issue addendum/ corrigendum/ errata.
Penalty u/s 271(1)(c) - defective show cause notice - the impugned SCN qualifies as a notice u/s 292B - it cannot be held to be invalid merely by mistake or defect of issuing it in a template and not scoring of the relevant ground and leaving out the applicable ground - Department allowed to issue addendum/ corrigendum/ errata.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
